ATTACHMENT A - NJ.commedia.nj.com/ledgerupdates_impact/other/Park, Sang-Hyun... · 2016. 11. 8. · “Huaying Lu,” and ... Amy Yang “Sung-Cha Yang,” ... Theresa M. Fanelli,

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ATTACHMENT A

Count One (Conspiracy)

From in or about June 2006 through on or about the date ofthis Criminal Complaint, in Bergen County, in the District of NewJersey and elsewhere, defendants

Known Name Alias(es)

Sang-Hyun Park “Jimmy,” “Jianfang Jiang,” and “Zhen Li”

Hyun-Jin LNU [last nameunknown]

“Hai Hua Xu”

Dong-Il Kim “Cai Juan Zhang,” and“Zhankun Liu”

Sung-Sil Joh “Jenny,” and “Zhanhong Fan”

Joong-Hyun Jung

Osung Kwon “Xiaoling Zhang”

Jin LNU “Jin,” “Zhaofang Chen,” and “Jianxin Jiang”

Min-Soo Son “Chris”

Young-Hee Ju “Stephanie,” and “Mingji Piao,”

Hyo-Il Song “Daniel,” “Yan Hua Wei,” “Haizhe Pei,” “Minghao Li,” and“Dongyun Zhou”

Dong-Won Kim “Andy Kim,” “Guangying Zhang,” “Huaying Lu,” and “Wei Yun Zhong”


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Seung-Ho Noh “Peter,” “Mr. Park,”“Zhong Z. Yin,”“Chae Yoon Lim,” and“Zhiquing Zhang”

Matthew J. Kang “Jun-Yong Kang”

Rita S. Kim “Rita Han”

Hyon-Suk Chung “Clara”

Young-Woo Ji “Fei Chen”

Sang-Kyu Seo

Hyun-Yop Sung “Shanji Li”

FNU [first name unknown] LNU#1

“Mr. Choi,” and “Xijun Gu”

Hyeon-U Kim “Deshang Zhang,” and “Xiurong Xu”

Edward M. Ha

Jong-Hoon Kim “John,”“Zhengshu An,”“Ruiping Chen,” and“Chun Shi Huang”

Chi-Won Jeon “Xianzi Luo,” and “Fengling Jin”

Jung-Hyuck Seo “Xiaoqin Zhang”

Jong-Kwan Hong “Dongshu Li”

In-Sook Lee “Susan,” and “Ping Fang”

Sung-Rok Joh “Zhang Li”

Jung-Bong Lee “Hong Guo Cui,” and “Wei Xiang Lu”

Hye-Won Jung “Meihong He”

Son-Hee Chong “Mingshun Yuan”

In-Suk Joo “Danhua Wang”


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Byung Jang “Pyung-Hak Jang,” and “Xue Hui Shi”

Amy Yang “Sung-Cha Yang,” “Yulan Qian” and “Amy Pitts”

Song-Ja Park “Run Hong Liu”

Min-Jun Kwon “Kwon Yi”

Jung-Sook Ko “Grace S. Lim,” and “Haishun Jin”

Myung-Kyun Ko “Longnan Cui”

Yoon-Hee Park “Yun-Hee Park,” “Zhangqi Zhang,” and“Xiaofang Zhu”

Alex S. Lee “Yicun Zhu,” and “Yun Hu”

Kyung-Ki Kim “Yuting Zhao”

knowingly and intentionally conspired and agreed with each otherand others to commit offenses against the United States by:

(1) producing without lawful authority identificationdocuments and false identification documents, inand affecting interstate and foreign commerce,contrary to Title 18, United States Code, Section1028(a)(1) and (c)(3)(A);

(2) knowingly transferring, possessing, and using,without lawful authority, a means ofidentification of another person with intent tocommit and in connection with unlawful activitythat constitutes a violation of federal law,including credit card fraud (18 U.S.C. § 1029),mail fraud (18 U.S.C. § 1341), wire fraud (18U.S.C. § 1343), bank fraud (18 U.S.C. § 1344), andbuying and selling social security cards andnumbers (42 U.S.C. § 408), in and affectinginterstate and foreign commerce, contrary to Title18, United States Code, Section 1028(a)(7);

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(3) buying and selling social security cards for thepurpose of obtaining things of value, contrary toTitle 42, United States Code, Section408(a)(7)(C); and

(4) with intent to defraud, trafficking in and usingone or more unauthorized access devices during anyone-year period, and by such conduct obtainingthings of value aggregating $1,000 or more duringthat period, contrary to Title 18, United StatesCode, Section 1029(a)(2).

In furtherance of the conspiracy and to effect its unlawfulobjects, the above-listed defendants and their co-conspiratorscommitted and caused to be committed the overt acts, amongothers, in the District of New Jersey and elsewhere, as set forthin Paragraphs 50 through 114 below of Attachment B.

In violation of Title 18, United States Code, Section 371.

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Count Two (Aggravated Identity Theft)

From in or about January 2009 through in or about October2009, in Bergen County, in the District of New Jersey andelsewhere, defendants

Sang-Hyun Park,a/k/a

“Jimmy,” “Jianfang Jiang,” and

“Zhen Li,” and

Hyun-Jin LNU,a/k/a

“Hai Hua Xu,”

during and in relation to violations of federal law, namely,credit card fraud (18 U.S.C. § 1029), mail fraud (18 U.S.C. §1341), wire fraud (18 U.S.C. § 1343), bank fraud (18 U.S.C. §1344), and fraud relating to social security cards and numbers(42 U.S.C. § 408), knowingly transferred, possessed, and used,without lawful authority, the means of identification of anotherperson, namely, Y.L., as described below in Attachment B, inviolation of Title 18, United States Code, Section 1028A andSection 2.

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Count Three (Aggravated Identity Theft)

From in or about January 2009 through in or about July 2009,in Bergen County, in the District of New Jersey and elsewhere, defendant

Young-Hee Ju,a/k/a

“Stephanie” and“Mingji Piao,”

during and in relation to violations of federal law, namely,credit card fraud (18 U.S.C. § 1029), mail fraud (18 U.S.C. §1341), wire fraud (18 U.S.C. § 1343), and fraud relating tosocial security cards and numbers (42 U.S.C. § 408), knowinglytransferred, possessed, and used, without lawful authority, themeans of identification of another person, namely, Mingji Piao,as described below in Attachment B, in violation of Title 18,United States Code, Section 1028A and Section 2.

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Count Four (Aggravated Identity Theft)

In or about February 2009, in Bergen County, in the Districtof New Jersey and elsewhere, defendant

Hyo-Il Song,a/k/a

Daniel,” “Yan Hua Wei,” “Haizhe Pei,”

“Minghao Li,” and“Dongyun Zhou,”

during and in relation to violations of federal law, namely,credit card fraud (18 U.S.C. § 1029), mail fraud (18 U.S.C. §1341), wire fraud (18 U.S.C. § 1343), and fraud relating tosocial security cards and numbers (42 U.S.C. § 408), knowinglytransferred, possessed, and used, without lawful authority, themeans of identification of another person, namely, Minghao Li, asdescribed below in Attachment B, in violation of Title 18, UnitedStates Code, Section 1028A and Section 2.

Count Five (Aggravated Identity Theft)

From in or about August 2009 through in or about October2009, in Bergen County, in the District of New Jersey andelsewhere, defendant

Dong-Won Kim,a/k/a

Andy Kim,” “Guangying Zhang,” “Huaying Lu,” and “Wei Yun Zhong”

during and in relation to violations of federal law, namely,credit card fraud (18 U.S.C. § 1029), mail fraud (18 U.S.C. §1341), wire fraud (18 U.S.C. § 1343), and fraud relating tosocial security cards and numbers (42 U.S.C. § 408), knowinglytransferred, possessed, and used, without lawful authority, themeans of identification of another person, namely, GuangyingZhang, as described below in Attachment B, in violation of Title18, United States Code, Section 1028A and Section 2.

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Count Six (Conspiracy to Commit Wire Fraud)

From in or about October 2009 through in or about December2009, in Bergen County, in the District of New Jersey andelsewhere, defendants



“Zhen Li,”

Hyun-Jin LNU,a/k/a

“Hai Hua Xu,”

Min-Soo Son, a/k/a “Chris,” and

Sang-Kyu Seo

knowingly and willfully conspired and agreed with each other andothers to devise a scheme and artifice to defraud the credit cardcompanies referred to in Paragraph 72 below of Attachment B, andto obtain money and property by means of materially false andfraudulent pretenses, representations, and promises, and to do soby means of interstate wire communications, as described inParagraph 72 below of Attachment B, contrary to Title 18, UnitedStates Code, Section 1343, in violation of Title 18, UnitedStates Code, Section 1349.

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Count Seven (Conspiracy to Commit Wire Fraud)

In or about January 2010, in Bergen County, in the Districtof New Jersey and elsewhere, defendants


“Jimmy,” “Jianfang Jiang,”

“Zhen Li,”

Hyun-Jin LNU,a/k/a

“Hai Hua Xu,”

Jong-Hoon Kim, a/k/a

“John,”“Zhengshu An,” “Ruiping Chen,”

“Chun Shi Huang,” and

Hag-Sang Jang


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Count Eight (Conspiracy to Commit Wire Fraud)

From in or about April 2010 through in or about May 2010, inBergen County, in the District of New Jersey and elsewhere,defendants



“Zhen Li,”

Hyun-Jin LNU,a/k/a

“Hai Hua Xu,”

Osung Kwon, a/k/a “Xiaoling Zhang,”

Yong Kim Lee, and

Hi-Joo Yang


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Count Nine (Money Laundering)

From on or about June 2009 through on or about July 2010, inBergen County, in the District of New Jersey and elsewhere,defendant Sang-Hyun Park, a/k/a “Jimmy,” “Jianfang Jiang,” and“Zhen Li,” knowingly conducted and attempted to conduct financialtransactions affecting interstate commerce and foreign, as morefully set forth in Paragraph 105 below of Attachment B, involvingthe proceeds of specified unlawful activity, namely, credit cardfraud (18 U.S.C. § 1029), mail fraud (18 U.S.C. § 1341), wirefraud (18 U.S.C. § 1343), and bank fraud (18 U.S.C. § 1344),knowing that the financial transactions were designed in wholeand in part to conceal and disguise the nature, location, source,ownership, and control of the proceeds of such specified unlawfulactivity, and knowing that the property involved in the financialtransactions represented proceeds of some form of unlawfulactivity, in violation of Title 18, United States Code, Section1956(a)(1)(B)(i) and Section 2.

Count Ten (Fraudulent Use of Identity Documents andAuthentication Features to Defraud the United States)

From in or about January 2010 through October 2010, inBergen County, in the District of New Jersey and elsewhere,defendant Sang-Hyun Park, a/k/a “Jimmy,” “Jianfang Jiang,” and“Zhen Li,” knowingly possessed identifications documents, falseidentification documents, and authentication features, includingsocial security numbers, to electrically file and transmit, causeto be electrically filed and transmitted, and to obtainfraudulent tax refunds from the United States to which he was notentitled, as described in Paragraphs 110 through 113 below ofAttachment B, to defraud the United States, namely, the InternalRevenue Service, in violation of Title 18, United States Code,Section 1028(a)(4) and Section 2.

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ATTACHMENT B

I, Theresa M. Fanelli, am a Special Agent with the FederalBureau of Investigation. I have knowledge of the facts set forthherein through my personal participation in this investigationand through oral and written reports from other federal agents orother law enforcement officers. Where statements of others areset forth herein, including statements that were intercepted orconsensually recorded, these statements are related in substanceand in part. Furthermore, these conversations, unless otherwiseindicated, occurred in the Korean language, and Your Affiant hasreviewed and relied on the translations of these conversations. Since this Criminal Complaint is being submitted for a limitedpurpose, I have not set forth every fact that I know or other lawenforcement officers know concerning this investigation. I haveonly set forth those facts that I believe are sufficient to showprobable cause exists to believe that the defendants havecommitted the offenses set forth in Attachment A. Where I assertthat an event took place on a particular date, I am assertingthat it took place on or about the date alleged.

The Defendants and Other Parties

At all times relevant to this Criminal Complaint:

1. Defendant Sang-Hyun Park, a/k/a “Jimmy,” “JianfangJiang,” and “Zhen Li,” a resident of Palisades Park, New Jersey,was the leader of a criminal enterprise that operated in northernNew Jersey and elsewhere.

a. Defendant Sang-Hyun Park operated out of severaloffices at the following locations: Brinkeroff Avenue, PalisadesPark, New Jersey (hereinafter the “Brinkeroff Office”), BroadAvenue, Palisades Park, New Jersey (hereinafter the “BroadOffice”), Bergen Boulevard, Palisades Park, New Jersey (hereinafter the “Bergen Boulevard Office”), and Bergen Turnpike,Ridgefield Park, New Jersey (hereinafter the “Bergen TurnpikeOffice”). Defendant Sang-Hyun Park and his co-conspirators oftenmoved offices to avoid detection by law enforcement. DefendantSang-Hyun Park was also the principal or owner/operator ofseveral fictitious shell companies, including SamsungConsulting/Top Consulting (hereinafter “Samsung Consulting”),Moja Trading Inc. (hereinafter “Moja”), Cocoxu Corporation(hereinafter “Cocoxu”), Li Nail Plus, Inc., d/b/a “Li Nails” and“Nails Plus” (hereinafter “Li Nail”), Ameth Thread Trading, Inc.(hereinafter “Ameth Thread”), and Mono Corporation (hereinafter“Mono Corp.”). Defendant Sang-Hyun Park registered his company,Li Nail, in the name of Zhen Li, a fraudulently obtained

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identity belonging to another person, as described below. Defendant Sang-Hyun Park established and used these companies forthe sole purpose of committing fraud.

b. To further the goals and aims of the criminalenterprise, defendant Sang-Hyun Park conspired with: (i)individuals employed by or associated with him who engaged inacts in furtherance of the criminal enterprise; (ii) “customers”who paid defendant Sang-Hyun Park and his co-conspirators foridentity documents and who enriched themselves by engaging inidentity fraud, credit card fraud, bank fraud, and tax fraud,among other crimes; (iii) brokers, suppliers, and manufacturersof identity documents, such as social security cards, immigrationdocuments, and genuine and counterfeit driver’s licenses; (iv) individuals who fraudulently increased the credit scoresassociated with fraudulently obtained identities that Sang-HyunPark’s sold and provided to his “customers”; and (v) collusivemerchants who charged or “swiped” fraudulently acquired creditcards for the purpose of defrauding banks and credit cardcompanies or who “fenced” or purchased merchandise, knowing thesame to have been purchased through the fraud (hereinaftercollectively the “Park Criminal Enterprise”).

Employees and Associates of Defendant Sang-Hyun Park

2. Defendant Hyun-Jin LNU, a/k/a “Hai Hua Xu,” was aresident of Ridgefield, New Jersey and was “second in command” ofthe criminal enterprise. Defendant Hyun-Jin LNU, a/k/a “Hai HuaXu,” is the registered agent of Cocoxu. In addition, defendantHyun-Jun LNU, using the Chinese name Hai Hua Xu, obtained aCertificate of Trade Name from Bergen County, New Jersey for CitiApparel Distributor and opened two business accounts at WachoviaBank in the name of Citi Apparel Distributor and Citi FashionWholesale, all of which were fictitious shell companies used tocommit fraud. (See Attachment C for photographs of Hyun-Jin LNU).

3. Defendant Dong-Il Kim, a/k/a “Cai Juan Zhang” and “Zhankun Liu,” was a resident of Ridgefield Park, New Jersey andan employee of defendant Sang-Hyun Park.

4. Defendant Sung-Sil Joh, a/k/a “Jenny” and “ZhanhongFan,” was a resident of Palisades Park, New Jersey. DefendantSung-Sil Joh was the owner/operator and registered agent of CelloHair, Inc., d/b/a Cello Hair Design, a hair salon businesslocated in Palisades Park, New Jersey (hereinafter “Cello Hair”).

5. Defendant Joong-Hyun Jung, was a resident of

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Palisades Park, New Jersey and an employee of defendant Sang-HyunPark.

6. Defendant Osung Kwon, a/k/a “Xiaoling Zhang,”was a resident of Palisades Park, New Jersey and an employee ofdefendant Sang-Hyun Park. Osung Kwon, using the name “XiaolingZhang,” was the registered agent of USA Apparel, Inc.(hereinafter “USA Apparel”), a fictitious shell company.

7. Defendant Jin LNU, a/k/a “Jin,” “Zhaofang Chen,” and“Jianxin Jiang,” was a resident of Flushing, New York. (SeeAttachment D for photographs of defendant Jin LNU).

8. Defendant Min-Soo Son, a/k/a “Chris,” was a resident ofRidgefield, New Jersey.

The Document Brokers

9. Defendant Young-Hee Ju, a/k/a “Stephanie” and“Mingji Piao,” was a resident of Closter, New Jersey and theowner/operator of My Fair Lady, a nail salon located in Montvale,New Jersey, and Blooming Nails 7, a nail salon located inChestnut Ridge, New York.

10. Defendant Hyo-Il Song, a/k/a “Daniel,” “Yan HuaWei,” “Haizhe Pei,” “Minghao Li,” and “Dongyun Zhou,” was aresident of Fort Lee, New Jersey. Defendant Hyo-Il Song was theprincipal of 153 Samsung DC, Inc. (hereinafter “153 Samsung DC”)and 90 You & Me Corporation (hereinafter “90 You and Me”).

11. Defendant Dong-Won Kim, a/k/a “Andy Kim,” “GuangyingZhang,” “Huaying Lu,” and “Wei Yun Zhong,” was a resident ofFlushing, New York.

12. Defendant Seung-Ho Noh, a/k/a “Peter” “Mr. Park,”“Zhong Z. Yin,” “Chae Yoon Lim,” and “Zhiquing Zhang,”was a resident Oakland Gardens, New York.

The Credit Build Up Teams

13. Defendant Matthew J. Kang, a/k/a “Jun-Yong Kang,” was aresident of Englewood Cliffs, New Jersey and the principal ofSummit Advisors Group, LLP, a purported financial advisorybusiness located in Englewood Cliffs, New Jersey.

14. Defendant Rita S. Kim, a/k/a “Rita Han,” was a residentof Fort Lee, New Jersey and the owner/operator of Shin YongConsulting, LLC, d/b/a Shin Hwa Consulting (hereinafter “Shin

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Hwa”), a purported financial consulting business located inPalisades Park, New Jersey.

15. Defendant Hyon-Suk Chung, a/k/a “Clara,” was a residentof North Bergen, New Jersey and the owner/operator of Shin Hwa.

16. Defendant Young-Woo Ji, a/k/a “Fei Chen,” is a residentof Bayside, New York.

The Collusive Merchants

17. Defendant Sang-Kyu Seo was a resident of PalisadesPark, New Jersey and the principal and owner/operator of Hang JinYi, Inc., d/b/a Hwangini, a room salon located in North Bergen,New Jersey. At this room salon, customers, primarily men, paidmoney for alcohol and the company of females.

18. Defendant Hyun-Yop Sung, a/k/a “Shanji Li,” was aresident of Carlstadt, New Jersey.

19. Defendant FNU LNU#1, a/k/a “Mr. Choi” and “XijunGu” was a resident of Little Ferry, New Jersey and theowner/operator of For Your Joy, LLC (hereinafter “For Your Joy”),a purported wholesale business located in Palisades Park, NewJersey. (See Attachment E for a photograph of defendant FNULNU#1).

20. Defendant Hyeon-U Kim, a/k/a “Deshang Zhang” and“Xiurong Xu,” was a resident of Flushing, New York and theowner/operator of Sunny Enterprise, a store front located inFlushing, New York.

21. Defendant Edward M. Ha was a resident of River Edge,New Jersey and a certified public accountant with an officelocated in Ridgefield, New Jersey.

22. Defendant Jong-Hoon Kim, a/k/a “John,” “Zhengshu An,”“Ruiping Chen,” and “Chun Shi Huang,” was a resident ofRidgefield, New Jersey and the owner/operator and principal ofRed Coco International, Inc. (hereinafter “Red Coco Int’l”), apurported wholesale seafood and grocery supply business locatedin Ridgefield, New Jersey.

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The Customers

23. Defendant Chi-Won Jeon, a/k/a “Xianzi Luo” and “Fengling Jin,” was a resident of Leonia, New Jersey.

24. Defendant Jung-Hyuck Seo, a/k/a “Xiaoqin Zhang,” was aresident of Palisades Park, New Jersey and the registered agentof Erin’s Skin Supply, Inc. (hereinafter “Erin’s Skin Supply”), apurported beauty supply business located in Palisades Park, NewJersey.

25. Defendant Jong-Kwan Hong, a/k/a “Dongshu Li,” was aresident of Westbury, New Jersey.

26. Defendant In-Sook Lee, a/k/a “Susan” and “PingFang,” was a resident of Palisades Park, New Jersey and employedat defendant Sang-Hyun Park’s business, Li Nail, d/b/a “Nails Plus,” in Hopatcong, New Jersey.

27. Defendant Sung-Rok Joh, a/k/a “Zhang Li,” was aresident of Palisades Park, New Jersey and the brother ofdefendant Sung-Sil Joh (see Paragraph 4 above).

28. Defendant Jung-Bong Lee, a/k/a “Hong Guo Cui” and “WeiXiang Lu,” was a resident of Palisades Park, New Jersey and theprincipal of Star 72 Jewelry Incorporated and Lu 72 Fashion, Inc.

29. Defendant Hye-Won Jung, a/k/a “Meihong He,” was a resident of Palisades Park, New Jersey and employed at defendantSang-Hyun Park’s business, Li Nail, d/b/a “Nails Plus,” inHopatcong, New Jersey.

30. Defendant Son-Hee Chong, a/k/a “Mingshun Yuan,” was aresident of Palisades Park, New Jersey.

31. Defendant In-Suk Joo, a/k/a “Danhua Wang,” was aresident of Clark, New Jersey.

32. Defendant Byung Jang, a/k/a “Pyung-Hak Jang” and “XueHui Shi,” was a resident of Fort Lee, New Jersey and the reportedowner/operator of Yuri Beauty Salon.

33. Defendant Amy Yang, a/k/a “Sung-Cha Yang,” “YulanQian” and “Amy Pitts,” was a resident of Palisades Park, NewJersey and the wife of defendant Sang-Kyu Seo (see Paragraph 17above).

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34. Defendant Song-Ja Park, a/k/a “Run Hong Liu,” was aresident of Ridgefield, New Jersey.

35. Defendant Min-Jun Kwon, a/k/a “Kwon Yi,” was a residentof Ridgefield, New Jersey and the son of defendant Song-Ja Park.

36. Defendant Hag-Sang Jang was a resident of PalisadesPark, New Jersey and the owner and operator of H and SConstruction Company (hereinafter “H and S Construction”), inPalisades Park, New Jersey.

37. Defendant Jung-Sook Ko, a/k/a “Grace S. Lim” and“Haishun Jin,” was a resident of Ridgefield, New Jersey.

38. Defendant Myung-Kyun Ko, a/k/a “Longnan Cui,” was aresident of Leonia, New Jersey. New M&K Global, Inc., a businessincorporated in New Jersey, was formed by an individual using thename Longnan Cui, a fraudulently obtained identity belonging toanother person, and purportedly operated out of a residence inRidgefield, New Jersey belonging to defendant Myung-Kyun Ko’ssister, defendant Jung-Sook Ko (see Paragraph 37 above).

39. Defendant Yoon-Hee Park, a/k/a “Yun-Hee Park,” “ZhangqiZhang,” and “Xiaofang Zhu,” was a resident of Flushing, New York.

40. Defendant Alex S. Lee, a/k/a “Yicun Zhu” and “Yun Hu,”was a resident of Palisades Park, New Jersey.

41. Defendant Yong Kim Lee, a/k/a “Yong Kim,” was a resident of Linden, New Jersey.

42. Defendant Hi-Joo Yang was a resident of Forest Hills,New York.

43. Defendant Kyung-Ki Kim, a/k/a “Yuting Zhao,” was aresident of Edison, New Jersey.

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44. Other Parties

a. An individual was cooperating with law enforcement(hereinafter “Cooperating Witness One”).

b. An individual was cooperating with law enforcement(hereinafter “Cooperating Witness Two”).

c. An individual was cooperating with law enforcement(hereinafter “Cooperating Witness Three”).

d. An individual was cooperating with law enforcement(hereinafter “Cooperating Witness Four”).

e. A co-conspirator, not named as a defendant herein,was a resident of Bergen County, New Jersey (hereinafter “Co-Conspirator One”).

f. An individual was a federal agent acting in anundercover capacity (hereinafter “Undercover Agent”).

Interception of Wire Communications–The Wire Taps

45. During this investigation, at various times, federalagents applied for and obtained Court ordered authorization tointercept wire communications occurring over the followingtelephone facilities:

a. a cellular telephone used by defendant Sang H.Park with phone number ending 4629 (hereinafter “First ParkTarget Facility”);

b. a cellular telephone used by defendant Sang H.Park with phone number ending 2579 (hereinafter “Second ParkTarget Facility”); and

c. a cellular telephone used by defendant Young-HeeJu with phone number ending 7792 (hereinafter “Ju TargetFacility”).

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Overview of the Criminal Enterprise

46. Defendant Sang-Hyun Park advertised in local Koreannewspapers and represented that he and his co-conspirators couldobtain driver’s licenses, credit cards, and money for theircustomers, virtually all of whom were of Korean descent.

47. Identity Theft and Use of Identity Documents

a. The Park Criminal Enterprise fraudulentlyobtained, brokered, and sold social security cards, socialsecurity numbers, and other identity documents to customers for afee of between approximately $5,000 and $7,000. Generally, thesesocial security cards began with the prefix “586.” These socialsecurity cards were issued by the United States to individuals,usually from China, who were employed in American territories,such as American Samoa, Guam, the Phillippines, and Saipan. Aspart of the fee, the Park Criminal Enterprise used these “586”social security cards and numbers (corresponding to Chinesenames) to either: (a) obtain and produce genuinely issueddriver’s licenses, identification cards, and other identitydocuments from various states; or (b) manufacture counterfeitdriver’s licenses and other counterfeit identity documents. These genuinely issued or counterfeit documents were obtainedthrough other brokers. The Park Criminal Enterprise obtainedout-of-state driver’s licenses and identification cards toexploit perceived weaknesses in those states’ issuing proceduresand to make it more difficult for bank employees in New Jersey todetect fraud and counterfeit documents.

48. The Credit Build Up

a. After brokering, obtaining, selling, and providingthese identity packages (i.e., social security card or number andgenuine or counterfeit driver’s license) to the customers, thePark Criminal Enterprise engaged in the fraudulent build up ofthe credit scores associated with the 586 identities.

b. This “credit build up” was accomplished by takingthe Chinese name and the corresponding 586 social security (i.e.,the Chinese identity) and attaching that identity, as anauthorized user, to various individual’s credit card accounts. The individuals involved in “credit build up” were members of orco-conspirators with the Park Criminal Enterprise, and theyreceived a fee for their “service,” knowing that the credit buildup was for the purpose of committing fraud.

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c. By attaching the Chinese identity to their creditcard accounts, these credit build up teams artificially increasedthe credit score associated with the Chinese identities tobetween 700 and 800. In reality, the individuals who providedthis “credit build up” service for the Park Criminal Enterprise’scustomers neither knew the actual person in whose name the buildup was being conducted (i.e., the Chinese identity) nor, invirtually every instance, the customer (i.e., the Koreanindividual using the identity). Furthermore, to deceive creditreporting agencies, credit card companies, banks, and lenders,the credit build up teams knowingly made false statementsconcerning the residency of these fraudulently obtained Chineseidentities.

d. The credit scores were relied on by banks, creditcard companies, finance companies, and lenders, among others,when deciding whether or not to issue credit or grant loans toconsumers. The main purpose of building these credit scores wasto profit by committing identity theft and financial fraud, asfurther described below.

49. The Various Schemes to Defraud

a. After the customer’s credit build up was completed, the Park Criminal Enterprise instructed, coached, andconspired with its customers to use the fraudulent identitieswith perfect or near perfect credit scores to open and obtainbank accounts, check books, credit cards (including store creditcards from merchants), debit cards, lines of credit, and loans,including loans guaranteed by the United States Small BusinessAdministration. The Park Criminal Enterprise often dispatchedits employees and associates to accompany its customers intobanks and retail stores for the purpose of opening accounts, applying for credit cards, and using these fraudulently obtainedcredit cards to purchase merchandise.

b. Thereafter, the Park Criminal Enterprise and itsco-conspirators, including its customers, enriched themselvesthrough the following schemes:

“Bust Out” Schemes

c. “The First Round”:

i. “Kkang.” The Park Criminal Enterpriseobtained cash from the fraudulently obtained credit cards throughthe practice of “kkang,” a slang Korean phrase referring to theuse of collusive merchants to obtain cash by charging or

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“swiping” fraudulently obtained credit cards. The Park CriminalEnterprise charged or “swiped” the credit cards on credit cardmachines possessed by wholly fictitious shell companies or othermerchants (hereinafter “Collusive Merchants”). After the moneyfrom these charges was transmitted into bank accountscorresponding to these credit card machines and/or collusivemerchants, the cash was withdrawn by the Park Criminal Enterpriseand its co-conspirators. For processing these credit cardtransactions–i.e., “kkang,” the Collusive Merchants received afee (i.e., a “kkang fee”).

ii. Purchase of Merchandise. The Park CriminalEnterprise also used, and directed its customers to use, thefraudulently obtained credit cards and retail credit (i.e., storecredit) to purchase at retail stores various goods, includingliquor, clothes, jewelry, sunglasses, handbags, and makeup, amongother things, which merchandise was sold to “fences” (i.e.,individual engage in the business of buying and selling stolen orfraudulently obtained goods) or retained for personal use.

d. “Second Round Bust Out.” After making these“first round” charges, the Park Criminal Enterprise then madepayments, either by telephone or by check, toward the chargesmade during the “first round.” These payments were almost alwaysdrawn against bank accounts opened with Chinese identities withcorresponding 586 social security numbers, and, in virtuallyevery instance, the payments were made with insufficient funds,resulting in the payments being returned. After the credit cardcompanies received these payments, but before the payments weredetermined to be fraudulent, the credit card companies creditedthe accounts, thereby allowing additional charges to be made onthese fraudulently obtained credit cards. Thereafter, the ParkCriminal Enterprise and its co-conspirators made additionalcharges on these credit cards, in much the same manner asdescribed during the “first round.” The Park Criminal Enterprisereferred to this part of the fraud as the “second round.” Ultimately, the charges from the first round and second roundwere not paid, resulting in significant losses to the victimcredit card companies.

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e. “Personal Bust Out.” At times and for a fee, thePark Criminal Enterprise “busted out” credit cards and lines ofcredit belonging to customers in their own name.

Bank, Loan, and Tax Fraud

f. Check-Kiting/”Check Jobs.” The Park CriminalEnterprise defrauded banks by engaging in check-kiting. Membersof the Park Criminal Enterprise deposited checks withinsufficient funds into bank accounts opened with Chineseidentities and corresponding 586 social security numbers. Afterdepositing these checks, they withdrew and attempted to withdrawmoney from these accounts before the banks discovered the fraud.

g. Cars. The Park Criminal Enterprise and its co-conspirators used the fraudulently obtained Chinese identitiesand corresponding 586 social security numbers to obtain loans andleases for high-end cars. After obtaining these cars, they usedthese cars for their personal use and enjoyment and/or sold andattempted to sell these cars.

h. Tax Fraud. The Park Criminal Enterprise used thefraudulently obtained Chinese identities and corresponding 586social security numbers to defraud the United States by, amongother ways, electronically filing false and fictitious taxreturns with the Internal Revenue Service and claiming andreceiving tax refunds based on these false and fictitiousreturns.

The Investigation of the Park Criminal Enterprise

The Brokers: Trafficking in Social Security Cards

50. In furtherance of the scheme, the Park CriminalEnterprise obtained, brokered, and sold to its customers genuinesocial security cards or numbers issued to actual persons. Forexample:

a. On or about September 17, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from defendant Dong-Won Kim. During thisintercepted conversation, defendant Dong-Won Kim asked if anyperson wanted to “do a New York license.” Defendant Sang-HyunPark asked, “Under what kind of conditions,” and defendant Dong-Won Kim replied, “No, without any conditions. For example, anykid who has 586 [social security number], or someone who had anold New York license but died, or ‘I have nothing, but want toget a license. . . .’” Defendant Sang-Hyun Park asked, “It’s

12

possible with people who had old license and died?” DefendantDong-Won Kim replied, “Yes, it’s possible.” Defendant Sang-HyunPark then stated, “I see. Let’s meet in person to talk aboutthat.”

b. On or about September 17, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from defendant Young-Hee Ju. During this call,defendant Sang-Hyun Park asked, “How is your business thesedays?,” and defendant Young-Hee Ju replied, “We have the nailshop and are busy doing visas and driver’s licenses.” Laterduring the conversation, defendant Young-Hee Ju asked, “[W]hatare you doing these days?,” and defendant Sang-Hyun Park replied,“I do everything, this and that, driver’s licenses . . . .”

c. On or about September 24, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from a yet to be identified Korean-speaking maleand prospective customer (“Customer”). The following discussionensued, in substance and in part:

Park: Yes, yes. Do you know [Dong-Il Kim]?Customer: Yes, I’m calling with big brother [defendant

Dong-Il Kim’s] introduction.Park: Yes, yes. Okay. I called you after I got a

call.Customer: Yes, yes. I called with [defendant Dong-Il

Kim’s] reference because I wanted to ask yousomething.

Park: Yes, yes. But you want to buy a social anddo a build-up?

Customer: Yes, I wanted to do something as big brother[defendant Dong-Il Kim] did.

Park: Ah, okay. . . . you are making it, this,because of money, right?

Customer: Right, I’m making it to make money.Park: Okay. Then do a social first, make an ID and

do a build-up and do those.Customer: Then, how long does it take?Park: About three months.

* * * *

Park: Yes. It costs $7,000 each every time you doit.

Customer: Well, if it works each time it comes, it’llbe worth investing, as I see it. (emphasisadded).

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* * * *

Park: First of all, if you want to do it, [you]have to make a social and then take a pictureand give it to us, we make you either an IDor a passport.

Customer: Yes.Park: And then, start a build-up and when . . .

finished, later, apply for a card and a loanas you open an account at the bank.

Customer: Ah, really? . . . . [H]ow much do I need togive you in the beginning?

Park: I get it all at once because all the fees goto . . . [do the] build up.

Customer: Ah, I have to give you all $7,000 at once?Park: Yes, and later we help you and the commission

we get is 8% of the money coming out.Customer: Ah, there’s another 8% on the money coming

out.Park: Yes, yes.Customer: Ah, really?Park: And we don’t take any of the fees in the

beginning up to a build up because we buy asocial and make an ID as well as a build up,we request it [through] build up businesspeople.

Customer: Yes, yes.Park: So, the money we get later is a fee since [we

do] the work.Customer: Ah, yes. The fee, do I give you or do you

take it out of [the money] coming out?Park: What? No, I get it out of the money coming

out.Customer: Right? Yes, yes.Park: You have to give it to me [Laughs].

d. On or about September 30, 2009, at approximately2:37 p.m., over the First Park Facility, defendant Sang-Hyun Parkmade an outgoing telephone call to defendant Matthew J. Kang. During this intercepted conversation, they discussed meetinglater that day. Defendant Sang-Hyun Park stated, “All the socialnumber [sic], I brought all the social card [sic].” DefendantMatthew J. Kang replied, “Yes, yes, yes. Okay.” They agreed tomeet at 4:30 p.m. that day.

e. On or about September 30, 2009, at approximately4:46 p.m., a law enforcement officer was conducting surveillancenear the Bergen Boulevard Office. During this surveillance, the

14

law enforcement officer observed and video recorded defendantMatthew J. Kang exit his black, BMW SUV with a brief case andenter the building in which the Bergen Boulevard Office islocated.

f. On or about September 30, 2009, at 5:25 p.m., overthe First Park Facility, defendant Sang-Hyun Park received anincoming telephone call from defendant Matthew J. Kang. Duringthis intercepted conversation, defendant Matthew J. Kang asked,“So, for checking accounts, I can open Bank of America and Citi,right?” Sang-Hyun Park responded, “No, and if all of their[social security numbers] start with 5 [586], and TD, PNC areokay. Open about six or seven accounts.”

g. On or about October 16, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from defendant Dong-Won Kim. During theconversation, defendant Dong-Won Kim asked, “You need a card,don’t you. . . . social?” Defendant Sang-Hyun Park replied thathe needed three, and defendant Dong-Won Kim responded that “theycame in today.” Defendant Dong-Won Kim stated that he purchasedthe social security cards for $800 each “so you can give me $800or $900. . . .” Defendant Dong-Won Kim stated he would send thesocial security cards to Los Angeles if defendant Sang-Hyun Parkcould not confirm his need for them. Defendant Sang-Hyun Park stated, “I will give you a call right after I confirm.”

h. On or about October 16, 2009, over the First ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant Matthew J. Kang. During the conversation,defendant Sang-Hyun Park said, “Mr. Matthew . . . [the personsaid] the social [security cards] came. . . . . That’s why Icalled to confirm to do it accurately.” Defendant Matthew J.Kang asked, “So, three, three of them came then?” Sang-Hyun Parkconfirmed that three social security cards had arrived. Defendant Sang-Hyun Park stated, “I have to pay for the social[s]first. . . .” Defendant Matthew J. Kang replied, “Well, I got Stephanie’s [defendant Young-Hee Ju] thing and brought it withme.” Defendant Matthew J. Kang stated, “I have the money now,”and defendant Sang-Hyun Park responded, “You don’t have to giveit [the money] to me today. You can give it tomorrow . . . . orMonday.”

i. On or about October 16, 2009, over the First ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant Dong-Won Kim. During the conversation, Sang-Hyun Park ordered three social security cards from defendantDong-Won Kim. Defendant Sang-Hyun Park stated, “Yes, three has

15

been [sic] confirmed. [Born 19]70s, males . . . . Doesn’t matterif [born in] 75, 76, 72. . . .”

j. On or about October 19, 2009, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Matthew J. Kang. During this interceptedconversation, defendant Matthew J. Kang stated, “One person . . .two people will start immediately and I was supposed to receiveit today but I haven’t received it yet.” Defendant Sang-HyunPark asked, “Social?” Defendant Matthew J. Kang stated, “Ireceived it along with ID.”

k. On or about December 19, 2009, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Dong-Won Kim. During this interceptedconversation, defendant Dong-Won Kim asked, “[Y]ou know the guy .. . who goes to Chicago from Flushing [New York], right? . . . .[Y]ou know [the individual] who did the social and license for IDjobs in the past. A Korean-American. . . . Yeah. He got caught.. . . the FBI came and arrested him.” Defendant Dong-Won Kimstated that this individual was the main supplier of socialsecurity cards. Defendant Sang-Hyun Park sighed and replied, “Iguess it’ll be hard to get the social [sic] from now on.” Defendant Dong-Won Kim then asked, “From whom do you get theCalifornia ones [driver’s licenses]? I used to get Californiaones from these guys, you know, making license and ID.” Defendant Sang-Hyun Park replied, “I ask Daniel for that now”[defendant Hyo-Il Song]. Defendant Sang-Hyun Park furtheradvised, “So Daniel, as a middleman, does it for me for $500 plussome express charge. . . . Since he’s close by, I ask him to makeit when he does his.” In addition, defendant Sang-Hyun Parkstated, “I used to do it with [a] passport and Nevada ID. . . .[b]ut I think you’d better make passport these days because oneof my clients in Flushing had problem opening Citibank usingNevada ID.” [As described below, defendant Sang-Hyun Park andhis co-conspirators obtain and sell counterfeit Nevada driver’slicenses]. Later during the conversation, defendant Sang-HyunPark stated the following:

[W]e went to the bank with the California ID [providedby defendant Hyo-Il Song] to test it. We had noproblem. . . . No problem at all. . . . . Ones fromNevada [driver’s licenses] there is no problem withones from Nevada too, but the price is expensive[meaning counterfeit Nevada driver’s licenses could beused to open bank accounts but were expensive to obtainfrom the counterfeiter]. Yeah, and Mr. Noh [defendantSeung-Ho Noh] is not known exactly for keeping

16

promises. You’re told it’ll be a week . . . .[g]ranted he’s not the one who does it, but [Mr. Noh]takes too much time and makes us worried. . . . [A]ndhe doesn’t do a clean job.

l. On or about December 23, 2009, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Dong-Won Kim. During this interceptedconversation, defendant Sang-Hyun Park asked, “That Saipan, fromwhere the driver’s license was issued? Was it from Saipan?” Defendant Dong-Won Kim replied, “Yes, yes, yes. No Chicago.” “Oh, from Illinois. . . . I guess it’s not a good idea to carryaround Illinois driver’s license[s] these days, huh?” defendantSang-Hyun Park asked. Defendant Dong-Won Kim replied, “No good,no good at all.” Defendant Sang-Hyun Park noted, “whether it’sreal or fake,” and defendant Dong-Won Kim replied, “right, right.. . . [n]o good. But that person got the original [socialsecurity card] by working in Saipan, in order to be able to applyfor the social, the permanent residency here.” Later in theconversation, defendant Dong-Won Kim remarked that he was “goingback and forth to Chicago.” [see Paragraph 67 below whereindefendant Dong-Won Kim, using 586 social security numbers,obtained approximately four driver’s licenses/identificationdocuments from Illinois].

m. On or about April 26, 2010, over the First ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant Dong-Won Kim. During this interceptedconversation, defendant Sang-Hyun Park asked defendant Dong-WonKim for two social security cards for customers born in the1960s. Defendant Dong-Won Kim replied, “Yes, I will ask [him].” Defendant Dong-Won Kim then asked, “[C]an you do Citi. . . . bust[it]?” Defendant Sang-Hyun Park replied that such credit cardswere the most difficult to defraud. Defendant Dong-Won Kimasked, “[H]ow about Chase, how do you do it after busting it?,”and defendant Sang-Hyun Park replied, “Purchase items and thensell them.”

n. On or about April 29, 2010, over the First ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant Dong-Won Kim. During this interceptedconversation, defendant Dong-Won Kim stated that he purchased asocial security card for $1,000 corresponding to a birth year of1968. Defendant Sang-Hyun Park instructed defendant Dong-Won Kimto bring the social security card to defendant Sang-Hyun Park,adding that he would pass on the cost of the social security cardto the customer.

17

Fraudulently Obtained Driver’s Licenses and Identity Cards

51. On or about the dates set forth below, in furtheranceof its criminal aims and goals, the Park Criminal Enterprise,using fraudulently obtained 586 social security cards and otherfalse documents, obtained and produced the following genuinelyissued but fraudulently obtained identity documents from theIllinois Department of Motor Vehicles (“IDMV”), the PennsylvaniaDepartment of Transportation (hereinafter “PennDOT”), theTennessee Department of Motor Vehicles (hereinafter “TDMV”), andthe California Department of Motor Vehicles (“CDMV”), as follows:

ApproximateDate

Defendant ChineseName/SSN

Type IssuingAuthority

June 22,2006

Seung-HoNoh

Zhong Z.Yin

586

driver’slicense (withphotograph)

IDMV

September7, 2006

Hyeon-UKim

DeshangZhang

586

identificationcard (withphotograph)

IDMV

March 22,2007

Young-HeeJu

Mingji Piao

586


IDMV

May 21,2007

Yoon-HeePark

ZhangqiZhang

586


IDMV

June 26,2007

Hyun-YopSung

Shanji Li

586


IDMV

July 10,2007

Hyo-IlSong

Yan Hua Wei

586


IDMV

September25, 2007

Chi-WonJeon

Xianzi Luo

586


IDMV

February 8,2008

Seung-HoNoh

Chae YoonLim

586


IDMV

ApproximateDate



18

February25, 2008

Sang H.Park

JianfangJiang

586


IDMV

February25, 2008

Dong-IlKim

Zhankun Liu

586


IDMV

February25, 2008

Young-WooJi

Fei Chen

586


IDMV

February25, 2008

In-SookLee

Ping Fang

586


IDMV

April 9,2008

Hyeon-UKim

Xiurong Xu

586


PennDOT

April 21,2008

Myung-Kyun Ko

Longnan Cui

586


IDMV

April 24,2008

Seung-HoNoh

ZhiquingZhang


IDMV

April 28,2008

Jong-HoonKim

Zhengshu An

586


IDMV

April 28,2008

Jong-HoonKim

RuipingChen

586


IDMV

May 12,2008

Sang-HyunPark

Zhen Li

586


IDMV

June 9,2008

Dong-WonKim

GuangyingZhang

586


IDMV

ApproximateDate



19

June 17,2008

Hyo-IlSong

Haizhe Pei

586


IDMV

June 19,2008

Dong-WonKim

GuangyingZhang

586


IDMV

June 30,2008

Dong-WonKim

Huaying Lu

586


IDMV

July 21,2008

Jin LNU ZhaofangChen

586


IDMV

July 21,2008

Jin LNU JianxinJiang

586


IDMV

July 22,2008

Jin LNU ZhaofangChen

586


IDMV

September4, 2008

Alex S.Lee

Yun Hu

586


PennDot

September19, 2008

Chi-WonJeon

FenglingJin

586


PennDOT

October 7,2008

Jong-HoonKim

Zhengshu An

586


IDMV

October 20,2008

Yoon-HeePark

XiaofangZhu


IDMV

ApproximateDate



20

October 27,2008

Sung-SilJoh

ZhanhongFan

586


IDMV

October 27,2008

Sung-RokJoh

Li Zhang

586


IDMV

October 27,2008

Jung-Hyuck Seo

XiaoqinZhang

586


IDMV

November11, 2008

Jong-HoonKim

Chun ShiHuang

586


IDMV

November17, 2008

Jung-BongLee

Hong GuoCui

586


IDMV

November17, 2008

Jung-BongLee

Hong GuoCui

586


IDMV

December30, 2008

Hyo-IlSong

Minghao Li

586


TDMV

January 12,2009

Hyun-JinLNULNU

Hai Hua Xu

586


IDMV

January 12,2009

Dong-WonKim

Wei YunZhong

586


IDMV

January 12,2009

FNU LNU#1 Xijun Gu

598


IDMV

ApproximateDate



21

January 20,2009

Jung-SookKo, a/k/a“GraceLim”

Haishun Jin

586


IDMV

January 20,2009

Jung-SookKo, a/k/a“GraceLim”

Haishun Jin

586


IDMV

January 20,2009

Jung-BongLee

Wei XiangLu

586


PennDOT

March 6,2009

Hyo-IlSong

DongyunZhou

586


PennDOT

January 26,2010

Dong-IlKim

Cai JuanZhang

586


CDMV

a. Each social security number referred to above wasnot issued by the United States to the referenced defendant.

b. According to Cooperating Witness Four, he/shedrove defendant Hyo-Il Song to Tennessee so defendant Hyo-Il Songcould obtain a Tennessee driver’s license using a Chinese alias.

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Trafficking and Use of Counterfeit Identity Documents

52. As described below, the Park Criminal Enterpriseobtains and sells counterfeit driver’s licenses, includingcounterfeit driver’s license purporting to be issued by Nevada,California, New York, and other states.

a. Defendant Sang-Hyun Park stated, over the FirstPark Facility, that defendant Seung-Ho Noh provides counterfeitNevada driver’s licenses (see Paragraph 50k above).

b. On or about September 30, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from defendant Seung-Ho Noh. During thisintercepted conversation, defendant Sang-Hyun Park stated, “Acustomer came and I thought ID came [for this customer] but ithasn’t. When did you say it’s coming this week? Which day?” Defendant Seung-Ho Noh replied, “It will come this weekend ornext Monday, I think. . . . It’s because it takes two weeks, andI took it last Saturday.”

c. On or about September 30, 2009, over the FirstPark Facility, defendant Sang-Hyun Park made an outgoingtelephone call to defendant Seung-Ho Noh. During thisintercepted conversation, defendant Sang-Hyun Park stated, “Andanother problem is that the name on one of the three IDs you gaveme last time was wrong. . . . so I told [the customer] to bringthe picture again, and I make a copy of the thing I gave you,president, and made copies of the things I gave these people . .. it’s the same but the name is different . . . . got the date ofbirth, social all the same but got the name wrong.” DefendantSeung-Ho Noh replied “Ah,” and defendant Sang-Hyun Park stated,“Yes, so when you come, you can re-do just that.” Based on thisconversation and other information set forth in this CriminalComplaint, Your Affiant believes that defendant Seung-Ho Nohproduces, transfers, and provides defendant Sang-Hyun Park withidentity documents, including counterfeit driver’s licenses,among other things, which fraudulently obtained and counterfeitdocuments the Park Criminal Enterprise and its co-conspiratorsuse for the purpose of committing fraud.

d. On or about November 4, 2009, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Seung-Ho Noh. During this interceptedconversation, defendant Sang-Hyun Park stated, “There’s anotherperson who needs an ID . . . . [but] if it keeps getting delayed,it’s too difficult for a middleman like me.” Defendant Seung-HoNoh asked, “How many people?,” and defendant Sang-Hyun Park

23

replied, “There are two people getting ready right now . . . .[b]ut I think there will be more in the future.” When defendantSang-Hyun Park asked why it took so long to obtain theidentifications, defendant Seung-Ho Noh replied, “They say it’sbecause it’s connected to a plane somehow but . . . . I heard ittakes long because [they] cross over like that and it’s made overthere and brought back.”

e. On or about November 10, 2009, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Seung-Ho Noh. During this interceptedconversation, defendant Seung-Ho Noh stated that he was en routeto defendant Sang-Hyun Park’s office and would arrive inapproximately twenty minutes. Defendant Sang-Hyun Parkinstructed defendant Seung-Ho Noh to hurry because defendantSang-Hyun Park had a “client waiting for ID.”

f. On or about November 12, 2009, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Seung-Ho Noh. During this interceptedconversation, defendant Seung-Ho Noh asked, “Do you have any IDsto do or not?” Defendant Sang-Hyun Park replied, “[I] do but Icouldn’t give it to you because people [sic] didn’t bring me themoney.” When defendant Seung-Ho Noh asked how manyidentifications were needed, defendant Sang-Hyun Park replied,“Two. I have to do two.”

g. On or about April 21, 2010, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Matthew J. Kang. During this interceptedconversation, the following discussion ensued, in substance andin part:

Park: In my opinion, we have so many problems here. . . we are having such a hard time becausewe are doing it with the out of state IDs. .. . That’s why the department stores andbanks are requesting supplemental documents. I don’t think there will be as many problemsas what we now have if we do it with locallyissued IDs, New York or New Jersey. At leastthey won’t tell us to send them something toverify the address. . . . Because we aredoing it with IDs issued in Las Vegas,Illinois, or California the banks seem to beconcerned about the authenticity of the IDs.

Kang: Right, right, the fakes.

24

h. On or about May 5, 2010, over the First ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant Hyun-Yop Sung. During this interceptedconversation, defendant Hyun-Yop Sung stated that he met “Daniel”[defendant Hyo-Il Song], and they [defendants Hyun-Yop Sung andHyo-Il Song] discussed the quality of counterfeit California andNew Jersey driver’s licenses. Defendant Hyun-Yop Sung stated:“The quality and everything else on the inside were exactly samebut . . . the one made in California . . . . It was made muchbetter than that. . . . They made the picture exactly same andgood but the color tone for this has a little bit of a fake look. The tone of the color of the one I made is a little darker,darker than the actual New Jersey license. So, I will get thepicture from President Daniel [defendant Hyo-Il Song] . . . . Andtell him to give me time, then I will make better one even thoughit takes time, about three weeks. I am going to get the pictureand make another one again that has a good color tone, though Iam not sure I will make [a] New York one and [a] New Jersey one.” Later during the conversation, defendant Hyun-Yop Sung tolddefendant Sang-Hyun Park, “And, about the credit card and checkjob [check-kiting] . . . . I am expecting to get them aroundFriday this week . . . . It is one for more than $50,000, so when I get them this week, I will put them together and give themto you this Saturday or Sunday.”

Use of Fraudulently Obtained Identities to CommitFraud—Customers of the Park Criminal Enterprise

53. Cooperating Witness One–First Chinese Identity

a. On or about January 20, 2009, Cooperating WitnessOne placed a consensually recorded telephone call to defendantSang-Hyun Park. Cooperating Witness One obtained defendant Sang-Hyun Park’s phone number from an advertisement in a Koreannewspaper. During this conversation, Cooperating Witness Oneasked defendant Sang-Hyun Park about obtaining a driver’slicense, and defendant Sang-Hyun Park responded that “we get liketen customers per day.” Defendant Sang-Hyun Park stated that inexchange for $3,500, he would arrange a trip for CooperatingWitness One to acquire a driver’s license. Defendant Sang-HyunPark stated that the money was needed to “buy the social[security card] here.” During this conversation, defendant Sang-Hyun Park stated that Cooperating Witness One would travel toChicago, Illinois with a “team.”

25

b. On or about January 21, 2009, a law enforcementofficer observed and photographed defendants Sang-Hyun Park, Hyo-Il Song, and FNU LNU#1, a/k/a “Mr. Choi” and “Xijun Gu,” walkinginto the Brinkerhoff Office.

c. On or about January 26, 2009, Cooperating WitnessOne met Sang-Hyun Park at the Brinkerhoff Office. During thisconsensually recorded meeting (audio and video), CooperatingWitness One handed $3,500 in cash to defendant Sang-Hyun Park,who handed the cash to defendant Hyun-Jin LNU to count. Laterduring the meeting, defendant Sang-Hyun Park explained thatCooperating Witness One would travel to Chicago with a “team” andwould thereafter return to New Jersey with a driver’s license andphoto identification. During this meeting, defendant Hyun-JinLNU acknowledged that she had also traveled to Chicago, Illinoisto obtain a driver’s license (see Paragraph 51 above andParagraph 58 below). Cooperating Witness One then adviseddefendant Sang-Hyun Park that he/she wanted the driver’s licenseto make money. Defendant Sang-Hyun Park replied that it wouldtake approximately two months to build the credit score beforeCooperating Witness One could use the driver’s license to obtaincredit cards. In addition, defendant Sang-Hyun Park stated thathe would charge Cooperating Witness One approximately $2,500 upfront to build up the credit score related to the identity andthe remainder of the fee would be paid after the credit build upwas completed. During this meeting, defendant Hyo-Il Song waspresent and inside the office.

d. On or about February 1, 2009, law enforcementofficers in New Jersey observed Cooperating Witness One meetdefendant Sang-Hyun Park outside the Brinkerhoff Office. Cooperating Witness One then departed in a car with an unknownco-conspirator. Thereafter, the next day, in Illinois, lawenforcement officers observed Cooperating Witness One meet withvarious, unknown co-conspirators. Thereafter, CooperatingWitness One was observed entering an IDMV facility. According toCooperating Witness One, when he/she arrived in Illinois, anunknown individual gave him/her a social security card beginningwith the prefix 586 in another person’s name with the initials“Y.L.”, a corresponding Chinese passport in the same name, and aletter falsely representing that Y.L. was a resident of Illinois. Cooperating Witness One, an individual of Korean descent, thenused these documents in the name of Y.L., a Chinese name, toprocure an Illinois driver’s license and an Illinois pictureidentity card in the name Y.L. (hereinafter collectively the“Y.L. Identity”). After traveling back to New Jersey,Cooperating Witness One gave the 586 social security card in thename of Y.L. and the corresponding driver’s license and picture

26

identity card to federal agents. The Chinese passport, accordingto Cooperating Witness One, was retained by an unknown co-conspirator.

e. Your Affiant and other agents have reviewed thesocial security card that Cooperating Witness One obtained inIllinois, the purchase of which social security card was brokeredby defendants Sang-Hyun Park and Hyun-Jin LNU. This socialsecurity card begins with the prefix 586.

f. On or about February 23, 2009, at the BroadOffice, during a consensually recorded meeting (audio and video), Cooperating Witness One paid defendant Sang-Hyun Park $2,500 as apartial payment for the build up of the credit score related tothe Y.L. Identity. During this meeting, Cooperating Witness Oneagreed to pay $1,500 to defendant Sang-Hyun Park, the remainingbalance for the credit build up, in about one and a half months.

g. After Cooperating Witness One obtained the Y.L.Identity documents through defendant Sang-Hyun Park and his co-conspirators, defendant Sang-Hyun Park directed CooperatingWitness One to open a Citibank checking account and obtain acellular phone using the Y.L. Identity. On or about February 25,2009, Cooperating Witness One telephonically called defendantSang-Hyun Park. During this consensually recorded call,defendant Sang-Hyun Park asked if Cooperating Witness One hadopened the Citibank account and obtained the phone. During thiscall, defendant Sang-Hyun Park told Cooperating Witness One tonot apply for a credit card at Citibank because the Y.L. Identityhad no credit. Defendant Sang-Hyun Park stated that CooperatingWitness One would obtain a credit card “after build up . . . .[and we] want to get a loan from [the bank] later on.” DefendantSang-Hyun Park stated that it would take approximately two monthsto complete the build up of the credit score associated with theY.L. Identity. Later during the conversation, CooperatingWitness One stated that he wanted to “get the most money out,”and defendant Sang-Hyun Park replied, “If we get the maximumamount out, that’s good for me too, for the both of us. So let’sdo that.”

h. On or about April 27, 2009, at the BergenBoulevard Office, Cooperating Witness One met defendants Sang-Hyun Park and Hyun-Jin LNU. During this consensually recordedmeeting (audio and video), defendant Sang-Hyun Park toldCooperating Witness One that the credit build related to the Y.L.Identity had been completed with a near perfect credit score. Thereafter, defendant Sang-Hyun Park explained how the build upof credit scores worked. Defendant Sang-Hyun Park explained that

27

the individuals who do “build up” attach or “plant” hiscustomer’s identity to other individuals’ credit, as anauthorized user, thereby making the customer’s credit score thesame as the primary account holder. As part of this process,defendant Sang-Hyun Park explained that the customer would thenassume the address of the primary account holder [therebyestablishing an address history for the customers, lendingvalidity to the individual’s bogus identity]. Later during themeeting, Cooperating Witness One paid defendant Sang-Hyun Parkapproximately $1,500 in cash for the completion of the build ofcredit related to the Y.L. Identity.

i. Cooperating Witness Three, who was arrested and isbeing prosecuted in another district, was interviewed by lawenforcement officers and admitted that he/she increased thecredit score of the Y.L. Identity by attaching the Y.L. Identity,as an authorized user, to his/her Citibank and Bank of Americacredit cards. Furthermore, Cooperating Witness Three stated thathe/she received a list of approximately ten to fifteen names,which included the Y.L. Identity, from defendant Hyun-Yop Sung,and Cooperating Witness Three added each name to his/her creditcards as authorized users. Cooperating Witness Three furtherstated that he/she was doing “credit build up” on the side tomake extra money. According to Cooperating Witness Three, he/sheneither knew nor met any of the individuals on the list and thathe/she knew that it was illegal and was fraud for individuals ofKorean ancestry to use identity documents belonging toindividuals of Chinese descent.

j. According to records from a credit reportingagency, the Y.L. Identity (i.e., social security number and name)was attached to the Citibank and Bank of America credit cardaccounts of Cooperating Witness Three. By attaching the Y.L.Identity to his/her credit cards as an authorized user,Cooperating Witness Three caused the credit score related to theY.L. Identity to be increased.

k. On or about May 5, 2009, at the Broad Office,Cooperating Witness One met defendant Sang-Hyun Park. Duringthis consensually recorded meeting (audio and video), defendantSang-Hyun Park directed Cooperating Witness One to go to Citibankto apply for a line of credit; PNC Bank to open a checkingaccount and apply for a credit card, Chase Bank to apply for acredit card; and TD Bank to apply for a credit card. Thereafter,defendant Sang-Hyun Park explained to Cooperating Witness One howthe scheme operated. Defendant Sang-Hyun Park stated that cashcould be withdrawn from lines of credit and that money could beobtained from credit cards through the practice of “kkang” [a

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Korean slang describing the use of collusive merchants to “bustout” credit cards, for a fee, to obtain cash].

l. On or about May 29, 2009, Cooperating Witness Oneentered the Broad Office. During this consensually recordedmeeting (audio and video), Cooperating Witness One provideddefendant Sang-Hyun Park with a PNC credit card in the name ofthe Y.L. Identity. Thereafter, defendant Sang-Hyun Park usedthis credit card to make a $100 charge through Cocoxu, a shellcompany used and controlled by defendant Sang-Hyun Park. YourAffiant believes that this charge was made to test whether or notthis credit card had been activated. According to CooperatingWitness One, he/she purchased neither goods nor services from orthrough this company. Defendant Sang-Hyun Park providedCooperating Witness One with a Cocoxu receipt, dated May 29,2009, in the amount of $100, which receipt Cooperating WitnessOne immediately provided to law enforcement.

m. On or about June 4, 2009, at the Bergen BoulevardOffice, Cooperating Witness One met defendant Sang-Hyun Park. During this consensually recorded meeting (audio and video),defendant Sang-Hyun Park explained how the “kkang” or “bust out”scheme worked. Defendant Sang-Hyun Park explained thatCooperating Witness One would charge up to the credit limit oneach credit card. Defendant Sang-Hyun Park stated thatCooperating Witness One would keep the money obtained throughbusting out the credit cards this first time, i.e., the “firstround.” Defendant Sang-Hyun Park further explained thatdefendant Sang-Hyun Park would then make some payments on themaxed out credit cards [for the purpose of keeping the account ingood standing] and then attempt to take out extra money for asecond time, i.e., “the second round.” Defendant Sang-Hyun Parkfurther explained that the credit cards would be “busted out” bycharging (or “swiping”) the cards through credit card machines. Your Affiant knows that, as part of this “bust out scheme,” thePark Criminal Enterprise makes charges on credit cards, usuallyat or near the credit limit on the credit card, and thereaftersubmits a payment (check or telephone payment) for those chargeswith insufficient funds. After the credit card company receivesthe payment but before the payment is determined to be fraudulent(i.e., the “float” period), the credit card company credits thepayment against the account, thereby permitting the possessor ofthe credit card or credit card number to make additional chargesagainst the account. Thereafter, the individual makes additionalcharges against the credit card with no intention of paying forany of these charges.

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n. At defendant Sang-Hyun Park’s direction,Cooperating Witness One used the fraudulently acquired driver’slicense in the name of Y.L. with a corresponding 586 socialsecurity card, to open checking accounts at TD Bank, PNC Bank,Citibank, and Chase Bank; to obtain a line of credit fromCitibank; and to apply for and obtain credit cards from Macy’s,Bloomingdales, Saks Fifth Avenue, Nordstrom, and Home Depot.

o. On or about June 4, 2009, defendant Sung-Sil Johaccompanied Cooperating Witness One to a TD Bank in Fairview, NewJersey for the purpose of opening a checking account using theY.L. Identity. After entering the bank, Cooperating Witness Oneand defendant Sung-Sil Joh spoke with a bank employee concerningopening the account. The meeting at the bank with CooperatingWitness One, defendant Sung-Sil Joh, and the bank employee wasrecorded (audio and video). During the meeting and in defendantSung-Sil Joh’s presence, Cooperating Witness One provided thefraudulently obtained driver’s license in the name of Y.L. to thebank employee for the purpose of applying for a credit card. When the bank employee asked Cooperating Witness One where he/shewas from, he replied, consistent with his false identity, thathe/she was from China. Thereafter, defendant Sung-Sil Joh, inthe Korean language, told Cooperating Witness One that he/she was“answering well” and that if he was in doubt about any of theanswers, that he/she should consult with her. While the bankemployee was completing the on-line credit card application,defendant Sung-Sil Joh, again in the Korean language, advisedCooperating Witness One that he/she could use the credit card atthe market where he worked. When Cooperating Witness One repliedthat he/she would be unable to use the credit card at that marketbecause they knew his true identity, defendant Sung-Sil Johreplied that he/she could falsely state that the identitybelonged to a friend. Defendant Sung-Sil Joh then advisedCooperating Witness One that he/she should not be nervous andthat if he had a problem at the bank, that he/she should requesta lawyer and not say “needless things” to the police or to policeinterpreters because the police could use the statements againsthim/her in court. Through this TD Bank account, approximatelyfive bad checks, totaling approximately $24,000 were depositedand later returned for insufficient funds, and approximately$4,200 in cash was withdrawn in furtherance of a check-kitingscheme.

p. On or about June 4, 2009, after defendant Sung-SilJoh and Cooperating Witness One returned from TD Bank, they wentto the Bergen Boulevard Office. Thereafter, from the BergenBoulevard Office, defendant Jung-Bong Lee drove defendant Hyun-Jin LNU, and Cooperating Witness One, and a yet to be identified

30

Korean female to Citibank in Totowa, New Jersey. After arrivingat the bank, defendant Hyun-Jin LNU escorted the unknown femaleinto the bank while Cooperating Witness One remained in the carwith defendant Jung-Bong Lee.

q. On or about June 8, 2009, a convenience check, inthe amount of $4,500 and drawn against a PNC credit card accountin the name of Y.L., was deposited into an account at Citibank inthe name of Limin Sun, a Chinese name with a corresponding 586social security number and a residential address previously usedby defendant Sang-Hyun Park.

r. On or about June 15, 2009, Cooperating Witness Onemet defendants Sang-Hyun Park and Hyun-Jin LNU at the BergenBoulevard Office. During this consensually recorded meeting(audio and video), defendant Sang-Hyun Park gave CooperatingWitness One approximately $3,825 in cash and stated that the cashrepresented Cooperating Witness One’s 85% profit from the scheme. Defendant Sang-Hyun Park referred to the remaining 15% as hiscommission. Defendant Sang-Hyun Park told Cooperating WitnessOne that to “make the big money” he/she needed to continue tomake small purchases on the credit cards. Immediately after thismeeting, Cooperating Witness One gave the $3,825 in cash tofederal agents.

s. On or about July 22, 2009, Cooperating Witness Onemet defendants Sang-Hyun Park and Hyun-Jin LNU at the BergenBoulevard Office. Defendant Byung Jang was present in the BergenBoulevard Office. During this consensually recorded meeting(audio and video), defendant Sang-Hyun Park told CooperatingWitness One that to make money on a Chase credit card, they hadto purchase merchandise and then resell it. Therefore, defendantSang-Hyun Park stated that Cooperating Witness One needed to maketime to shop. Defendant Byung Jang added that retail stores werebecoming increasingly cautious about certain charges. Laterduring the conversation, defendant Byung Jang stated that heintended to establish a new business once he received a lump sumfrom a bust out scheme. Defendants Sang-Hyun Park, Hyun-Jin LNU,and Byung Jang suggested that Cooperating Witness One go toretail stores, like Nordstrom, Best Buy, and Home Depot, to applyfor credit cards. Defendant Sang-Hyun Park then gave CooperatingWitness One approximately $4,300. In addition, defendants Sang-Hyun Park and Hyun-Jin LNU gave Cooperating Witness Onehandwritten documents, reflecting the accounts opened using theY.L. Identity, the corresponding maximum credit limits for eachcredit card, and the breakdown of the cash due to CooperatingWitness One resulting from defendant Sang-Hyun Park’s busting outof credit cards. Immediately after this meeting, Cooperating

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Witness One gave the $4,300 in cash and documents to federalagents.

t. On or about August 31, 2009, a telephone paymentwas made for the Y.L. Macy’s Visa account in the amount of$2,914.95. On or about September 3, 2009, this payment wasreturned because of insufficient funds. In addition, on or aboutAugust 31, 2009, a telephone payment was made for the Y.L.Bloomingdale’s Visa account in the amount of $2,900. On or aboutSeptember 8, 2009, this payment was returned because ofinsufficient funds. Your Affiant believes that these facts areconsistent with “busting out” credit cards, as defendant Sang-Hyun Park had explained to Cooperating Witness One.

u. At various times after Cooperating Witness Onereceived credit cards obtained with the Y.L. Identity, he/sheprovided the credit cards to defendant Sang-Hyun Park. Thefollowing table sets forth some of the fraudulent charges made orcaused to be made by defendant Sang-Hyun Park and his co-conspirators with the fraudulently acquired Y.L. Identity creditcards, among others:

Date Type of CreditCard

Amount Description

June 8,2009

PNC Visa $4,500 Convenience check cashedat PNC Bank

June 22,2009

PNC Visa $850 Charge through Cocoxu

June 26,2009

Macy’s Visa $1,790 Charge through ErinsSupply.

June 26,2009

BloomingdalesVisa

$1,350 Charge through Cocoxu

June 29,2009

Macy’s Visa $300 Charge through Cocoxu

July 6,2009

BloomingdalesVisa

$780 Charge through Li NailsPlus.

July 31,2009

Chase Visa $7,053.52 Charge through a liquorstore in Palisades Park,New Jersey.

August 1,2009

Chase Visa $1,500 Charge through “Hang JinYi” [defendant Sang-KyuSeo’s room salon]


Amount Description

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August20, 2009

PNC Visa $1,000 Charge through “Hwangini”[defendant Sang-Kyu Seo’sroom salon]

September2, 2009

Macy’s Visa $2,896.81 Charge through Li NailsPlus.

September2, 2009

Bloomingdale’sVisa

$2,815.79 Charge through ErinsSupply.

September3, 2009

Macy’s Visa $100 Charge through New M andK Global

September3, 2009

Bloomingdale’sVisa

$50 Charge through New M andK Global

The above charges were not made for the purchase of goods orservices but rather to “bust out” (i.e., “kkang”) the creditcards obtained by Cooperating Witness One, at defendant Sang-HyunPark’s direction, using the fraudulently obtained Y.L. Identity. Furthermore, according to records from each credit card companyreferred to in the above table, the charges were not paid,resulting in a loss to each company.

v. On or about September 5, 2009, defendants Hyun-JinLNU and Dong-Il Kim entered a liquor store in Hackensack, NewJersey and purchased fives cases of Johnnie Walker Black and onecase of Johnnie Walker Blue, costing approximately $3,170.77. Law enforcement officers obtained and reviewed a security videofrom this liquor store that shows defendant Dong-Il Kim handing acredit card to the merchant and signing a receipt. Recordsobtained during this investigation have revealed that thispurchase was made using a Chase credit card in the name of Y.L.,the identity purchased by Cooperating Witness One from defendantSang-Hyun Park and his co-conspirators, as described above. Furthermore, the receipt contains a number and date of birthcorresponding to the number and date of birth on the Illinoisidentification card obtained by Cooperating Witness One in thename of Y.L.

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w. Defendant Sang-Kyu Seo is the owner and operatorof Hang Jin Yi, Inc., d/b/a Hwangini. On or about September 8,2009, over the First Park Facility, defendant Sang-Hyun Park madean outgoing telephone call to defendant Sang-Kyu Seo. Duringthis intercepted conversation, defendant Sang-Hyun Park stated,“I bought the liquor.” Defendant Sang-Kyu Seo replied, “Howmuch? Okay, I got it.” Defendant Sang-Hyun Park replied,“Black, one, two, three, four, about five. Five or four boxes. And one box of blue, blue.” (see Paragraph 53v above, whereindefendants Hyun-Jin LNU and Dong-Il Kim used a fraudulentlyacquired credit card, obtained using the fictitious identity ofCooperating Witness One, to purchase fives cases of JohnnieWalker Black and one case of Johnnie Walker Blue).

x. On or about September 8, 2009, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Sang-Kyu Seo. During this interceptedconversation, defendant Sang-Kyu Seo stated, “Bring the liquor tothe store later, five [boxes] of black and one box of blue.” Later during the conversation, defendant Sang-Kyu Seo asked, “Isthe work for my little one going well?” Defendant Sang-Hyun Parkreplied, “ID will arrive tomorrow or not later than the dayafter. . . .”

y. On or about September 8, 2009, over the First ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant Sang-Kyu Seo. During this interceptedconversation, the following discussion ensued, in substance andin part:

Park: Big brother, I can’t go. I’ll send Dong Il[defendant Dong-Il Kim].

Seo: Oh.Park: Black five box[es] and blue one box.Seo: Yeah, I know.Park: So, it’s $1,980.Seo: Why is it $1,980, man?

* * * *

Park: I got $2,500 for twelve bottles last time. .. . I got $2,160 for three boxes of JohnnyBlue. You gave me $4,660, big brother.

Seo: Ah.Park: That’s true. It’s still 40% cheaper,

according to my calculation. . . .

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z. On or about September 25, 2009, CooperatingWitness One met defendants Sang-Hyun Park and Hyun-Jin LNU at theBroad Office. During this consensually recorded meeting (audioand video), defendant Sang-Hyun Park told defendant Hyun-Jin LNUto pay Cooperating Witness One approximately $7,283. DefendantSang-Hyun Park stated that this cash represented CooperatingWitness One’s share from the bust out scheme. Thereafter,defendant Hyun-Jin LNU gave Cooperating Witness One approximately$7,283 in cash. Immediately after the meeting, CooperatingWitness One provided the $7,283 in cash to federal agents.

aa. On or about October 23, 2009, a federal income taxrefund in the amount of $6,987 was electronically transmittedinto the Y.L. Identity’s Citibank Account. This account wasopened by Cooperating Witness One at defendant Sang-Hyun Park’sdirection, and defendants Sang-Hyun Park and Hyun-Jin LNUcontrolled and had access to this account because, among otherways, defendant Hyun-Jin LNU establish on-line banking for thisaccount. The 2008 federal income tax return associated with thisrefund was electronically filed on or about October 14, 2009 inthe name of “Shunyu Li” with a corresponding 586 social securitynumber and with reported address in Palisades Park, New Jersey. A Form W-2 in the name of Shunyu Li was electronically submittedin support of the tax return. The Form W-2 claimed that ShunyuLi was employed by a casino in Atlantic City, New Jersey;however, according to this casino, no individual by that namewith that social security number was employed by the casino. Accordingly, Your Affiant believes that both the tax return andForm W-2 in the name of Shunyu Li are fraudulent. Approximatelythree days after the $6,987 return was credited into the account,a check in the amount of $7,000, drawn on this account, was madepayable in the name of “Li Zhang” a Chinese identity used bydefendant Sung-Rok Joh.

54. Cooperating Witness One–Second Chinese Identity

a. On or about January 23, 2010, Cooperating WitnessOne met defendants Sang-Hyun Park and Hyun-Jin LNU at the BergenTurnpike Office. During this consensually recorded meeting(audio and video), Cooperating Witness One stated that he/shewanted to make more money, and defendant Sang-Hyun Park replied,“You want to do it again?” Defendant Sang-Hyun Park stated thatthey could make approximately $50,000. When Cooperating WitnessOne asked how much he/she would be required to pay up front,defendant Sang-Hyun Park said it would cost approximately $7,000. Defendant Sang-Hyun Park explained that it was more difficult tocarry out the scheme because it was becoming more difficult toobtain social security cards, especially 586 social security

35

cards. When Sang-Hyun Park asked Cooperating Witness One ifhe/she still had the Chinese 586 social security card [referringto the Y.L. Identity], Cooperating Witness One stated that he/shehad discarded it. Sang-Hyun Park replied, “No big deal, it’sfinished anyway. It’s very difficult to get a new one.” Defendant Sang-Hyun Park explained that he could no longer sendhis customers to Illinois to obtain driver’s licenses because theIDMV had revoked numerous driver’s licenses after learning thatthe addresses used to obtain those licenses were false. Defendant Sang-Hyun Park then explained that they could makemoney using a United States identification “so we go forge theID.” Defendant Sang-Hyun Park stated that the banks would acceptcounterfeit driver’s licenses. When the Cooperating Witness Oneexpressed concern about getting caught, defendant Sang-Hyun Parkstated, “It has very low risk. Simply put, with a picture, thisis how we do it.” At this point in the conversation, defendantSang-Hyun Park showed Cooperating Witness One a sample of aprevious customer’s documents (which documents were captured onthe video recording): a social security card [number notrecognizable on the video recording], a California driver’slicense, and a green card. Cooperating Witness One asked for adiscount ($6,000 instead of $7,000), but defendant Sang-Hyun Parkreplied that he could not give a discount because he would notmake any money. Defendant Sang-Hyun Park advised CooperatingWitness One it would take approximately one week to make theidentification, and the credit build up would take approximatelyone month. Defendant Sang-Hyun Park explained that CooperatingWitness One needed to provide two photographs, and thatCooperating Witness One would receive a California driver’slicense.

b. On or about April 10, 2010, Cooperating WitnessOne met defendants Sang-Hyun Park and Hyun-Jin LNU at the BergenTurnpike Office. During this consensually recorded meeting(audio and video), defendant Sang-Hyun Park stated thatCooperating Witness One would receive a fake California driver’slicense and a social security card. Defendant Sang-Hyun Parkacknowledged that the social security card was real. DefendantSang-Hyun Park then directed defendant Hyun-Jin LNU to takeCooperating Witness One’s pictures and his/her money. Thereafter, Hyun-Jin LNU took $7,000 in cash from CooperatingWitness One and counted it.

c. On or about May 8, 2010, Cooperating Witness Onemet defendants Sang-Hyun Park and Hyun-Jin LNU at the BergenTurnpike Office. During this consensually recorded meeting(audio and video), Cooperating Witness One received a counterfeitCalifornia driver’s license and a 586 social security card in the

36

name of an individual with the initials “J.Z.” (hereinafter the“J.Z. Identity”). Defendant Sang-Hyun Park advised CooperatingWitness One that the counterfeit driver’s license could only beused to open bank accounts (i.e., that Cooperating Witness Oneshould not use it to drive). Later during the meeting, defendantHyun-Jin LNU gave Cooperating Witness One a “post it” note with aphone number and instructed Cooperating Witness One to call herif Cooperating Witness One had any questions.

d. On or about August 3, 2010, Cooperating WitnessOne returned a telephone call to defendant Hyun-Jin LNU that shemade to Cooperating Witness One several days before. During thisconsensually recorded conversation, defendant Hyun-Jin LNU saidthat the credit build up was completed and that CooperatingWitness One needed to start going to the banks with them to openaccounts.

e. On or about August 19, 2010, defendant Hyun-JinLNU called Cooperating Witness One. During this consensuallyrecorded phone call, defendant Hyun-Jin LNU stated that the buildup of credit related to the J.Z. Identity had been completed, andthat it was time to open bank accounts.

55. Cooperating Witness Two

a. On or about March 17, 2009, Cooperating WitnessTwo called defendant Sang-Hyun Park. During this consensuallyrecorded telephone call, Cooperating Witness Two told Sang-HyunPark that he/she was an illegal alien, having remained in theUnited States after his/her tourist visa had expired. DefendantSang-Hyun Park stated that he would have a person specializing inobtaining driver’s licenses return Cooperating Witness Two’scall. Cooperating Witness Two asked if defendant Sang-Hyun Parkwas in charge, and he stated he was “in charge of loans.”

b. On or about March 18, 2009, Cooperating WitnessTwo called defendant Sang-Hyun Park and again asked him aboutobtaining a driver’s license. Defendant Sang-Hyun Park askedCooperating Witness Two if he/she had a social security number. Cooperating Witness Two replied that he/she did not have a socialsecurity number. During a subsequent call on the same day,defendant Sang-Hyun Park stated that he would have anotherperson contact Cooperating Witness Two to assist him/her obtain adriver’s license.

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c. Later that day, over the Ju Facility, defendantYoung-Hee Ju called Cooperating Witness Two. During thisconsensually recorded conversation, defendant Young-Hee Ju statedthat she had contacted Cooperating Witness Two at defendant Sang-Hyun Park’s request. After Cooperating Witness Two inquiredabout obtaining a driver’s license, defendant Young-Hee Ju statedit would cost Cooperating Witness Two approximately $3,500 plusair fare.

d. On or about March 25, 2009, Cooperating WitnessTwo, under the supervision and direction of law enforcementofficers, met defendant Young-Hee Ju at a location in PalisadesPark, New Jersey. During this consensually recorded meeting(audio and video), defendant Young-Hee Ju stated, among otherthings, that it would cost Cooperating Witness Two approximately$4,000 for a driver’s license and social security card andanother $2,500 to establish and build credit using thesefraudulently acquired identity documents.

e. On or about April 8, 2009, Cooperating Witness Twomet defendant Young-Hee Ju at a location in Palisades Park, NewJersey. During this consensually recorded meeting (audio andvideo), defendant Young-Hee Ju stated that Cooperating WitnessTwo would be required to pay approximately $2,000 as a depositfor a social security card. Cooperating Witness Two then handed defendant Young-Hee Ju approximately $2,000 in cash, anddefendant Young-Hee Ju gave Cooperating Witness Two a socialsecurity card beginning with the prefix 586 corresponding to aChinese name with the initials Y.F.Z. (hereinafter the “Y.F.Z.Identity”). In addition, defendant Young-Hee Ju explained thatCooperating Witness Two needed to provide two passportphotographs. Defendant Young-Hee Ju also told CooperatingWitness Two that he/she would be required to pay an additional$2,500 to build the credit score related to the Y.F.Z. Identity,which process would take approximately two months. DefendantYoung-Hee Ju then explained how the credit build up would work:

Think of it like this. You have [your] own [real]social [security]. Think of it [the Y.F.Z. Identity]like it’s [your] social. With [your] social, it hasbeen built up with time [referring to credit score],but with this, it needs to be built up quickly. So, itneeds to be paired as joint account holder with othersof 800 [credit] scores. Then they will set up jointaccounts with three accounts and charge $2,500, $800[per] account. And if [the Y.F.Z. Identity is] pairedwith three [accounts], then the [credit] score becomes790. Then once you apply for credit cards, they will

38

pull out all [the money]. [They will] withdraweverything. . . .

* * * *

Have to raise the [credit] score. It’s $2,500, butthis place [the credit build up team] is cheap and[they] definitely raise [your credit] score. . . . Thenonce the score is about to be released, then [you can]go get an ID and right into the bank. Understand now?

f. On or about May 14, 2009, defendant Young-Hee Juand Cooperating Witness Two met in Palisades Park, New Jersey. During this consensually recorded meeting (audio and video)Cooperating Witness Two gave defendant Young-Hee Ju approximately$2,500 in cash to pay for the first phase of the credit build up. During this meeting, defendant Young-Hee Ju stated that she wasjust a “gofer” for the credit build up process, and that theindividuals who provide the credit build up service always charge“our” customers $2,500. As described below, defendant Matthew J.Kang did the credit build up for Cooperating Witness Two’sChinese identity.

g. On or about July 21, 2009, Cooperating Witness Twomet defendant Young-Hee Ju at a location in Bergen County, NewJersey. During this consensually recorded meeting (audio andvideo), Cooperating Witness Two gave defendant Young-Hee Juapproximately $1,500 in cash and two passport photographs for thepurchase of a Chinese passport.

h. On or about July 21, 2009, over the Ju Facility,defendant Young-Hee Ju made an outgoing telephone call todefendant Sang-Hyun Park. During this intercepted conversation,defendant Young-Hee Ju stated, “Yes. Yes. It’s me.” Sang-HyunPark responded, “Oh, yes. How are you?” Young-Hee Ju thenstated, “I received the photos and things from someone who wishesto get a passport.” Defendant Sang-Hyun Park asked, “A Chinesepassport?,” and defendant Young-Hee Ju said “Yes.” Sang-HyunPark then told Young-Hee Ju to bring it to him in the evening. During a subsequent intercepted conversation later that day, theydiscussed an individual arrested in another district. DefendantSang-Hyun Park stated “[t]he problem started when he [arrestee]was involved with people who make driver licenses in [anotherstate]” but the arrest was “completely unrelated to this sidehere.” Defendant Young-Hee Ju then remarked that “people wereconcerned. That’s why I wanted to talk.” Defendant Sang-HyunPark responded, “People over there got caught. . . . [n]ot here.. . .” Defendant Sang-Hyun Park and defendant Young-Hee Ju then

39

discussed “the person who applied for the passport [referring toCooperating Witness Two].” Defendant Sang-Hyun Park stated heneeded an address to send the passport to [Cooperating WitnessTwo] via federal express. Defendant Young-Hee Ju stated that shereceived $1,500 from “the person [Cooperating Witness Two].” Defendant Sang-Hyun Park said that $1,000 is what he pays to “theperson who does it [creates the passport].” Defendant Sang-HyunPark told defendant Young-Hee Ju to get a photograph and askedfor $100 on top of the $1,000 fee.

i. On or about September 17, 2009, CooperatingWitness Two met defendant Sang-Hyun Park at the Broad Office. During this consensually recorded meeting (audio and video),defendant Sang-Hyun Park gave Cooperating Witness Two acounterfeit Nevada driver’s license in the name of Y.F.Z., whichname corresponds to a 586 social security number issued to anindividual with the name Y.F.Z.

j. On or about September 17, 2009, over the FirstPark Facility, defendant Sang-Hyun Park made an outgoingtelephone call to defendant Young-Hee Ju. During thisintercepted conversation, Cooperating Witness Two was present indefendant Sang-Hyun Park’s Broad Office. During this interceptedconversation, defendant Sang-Hyun Park stated, “I gave[Cooperating Witness Two] the ID and [he/she] made it sound likethe build up is completed. So I wanted to open it and discussit. . . . [but] [w]hen I opened it [checked the credit history],there is nothing.” Defendant Young-Hee Ju replied, “I will talkto [Cooperating Witness Two].” Thereafter, defendant Sang-HyunPark placed Cooperating Witness Two on the phone, and defendantYoung-Hee Ju stated, “ID is finished. One thing is missing fromthe build up. Ask Mr. Park [defendant Sang-Hyun Park]. Thebuild up is becoming difficult.” Cooperating Witness Two asked,“Who is going to do mine [the build up associated with thefraudulently purchased identity]?” Defendant Young-Hee Jureplied, “There is someone who can do it here. There is someonewho sells it. It’s selling my credit.” Cooperating Witness Twothen asked, “I asked for money and making card because I needmoney quickly.” Defendant Young-Hee Ju stated, “We’ll explainthat after this comes out. But the score isn’t ready.” Laterduring the conversation, defendant Young-Hee Ju informeddefendant Sang-Hyun Park that the build up of credit related tothe identity purchased by Cooperating Witness Two was beingcompleted by Shin-hwa [a company owned and operated by defendantsRita S. Kim and Hyon-Suk Chung; see Paragraph 103 below], andthat the build up was not successful and had to be re-done. Defendant Young-Hee Ju stated, “We only work with them[defendants Rita S. Kim and Hyon-Suk Chung]. But it didn’t work.

40

They have work backed up. So they said to wait.” DefendantSang-Hyun Park replied that he would explain the situation toCooperating Witness Two. Defendant Sang-Hyun Park then stated,“And let’s meet. I have a loan that works.” Based on thisconversation (as intercepted over the First Park Facility and asconsensually recorded (audio and video) by Cooperating WitnessTwo, Your Affiant believes that defendants Sang-Hyun Park andYoung-Hee Ju agreed to provide a fraudulently obtainedidentification to Cooperating Witness Two but that defendantYoung-Hee Ju would use a separate team [defendants Rita S. Kimand Hyon-Suk Chung] to build the credit related to thisfraudulently obtained identity.

k. On or about October 22, 2009, Cooperating WitnessTwo met defendant Sang-Hyun Park at the Bergen Turnpike Office. During this consensually recorded meeting (audio and video),defendant Sang-Hyun Park stated that the build up of the creditscore associated with the Y.F.Z. Identity was not correctlycompleted because the address on the credit report had not beenverified and therefore the build up needed to be re-done.

l. On November 5, 2009, Cooperating Witness Two metdefendant Sang-Hyun Park at the Bergen Turnpike Office. Duringthis consensually recorded meeting (audio and video), defendantSang-Hyun Park gave Cooperating Witness Two a fictitious PSE&Gutility bill with a fictitious address, which fraudulent documentwas created by Hyun-Jin LNU on a computer. Thereafter, defendant Sang-Hyun Park advised Cooperating Witness Two to open a CitibankGold Plus account, using the Y.F.Z. Identity, and to placeapproximately $500 in the account. Defendant Sang-Hyun Parkprovided Cooperating Witness Two with the information he/shewould need to open this account, including fictitious employmentinformation and income ($55,000). This fictitious informationwas provided to Cooperating Witness Two on a piece of paper thatwas written by Hyun-Jin LNU and then provided to law enforcmentby Cooperating Witness Two.

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56. The Undercover Operation

a. On or about May 7, 2010, the Undercover Agent,posing as a potential customer, met with defendants Sang-HyunPark, Hyun-Jin LNU, and Dong-Il Kim at the Bergen TurnpikeOffice. During this consensually recorded meeting (audio), theUndercover Agent stated that he/she had heard that he/she couldmake money through defendant Sang-Hyun Park. Defendant Sang-HyunPark then explained how the scheme worked:

What we do here is, there are those who come herelegally but don’t live here and go back . . . . Wemostly do this with Chinese people’s [sic]. . . .[Undercover Agent: “So it’s not going to be a Koreanname?”] Right, so if I can show you a sample[defendant Sang-Hyun Park then showed him/her numerousdriver’s licenses, as samples, from other customers]. .. . This social is not fake. It’s real. . . . It’sreal but this person isn’t here. . . . That’s important. . . . If we use someone else’s [social] here, itbecomes stealing, right?. . . . But this one, theperson went back to his country. . . . (emphasisadded).

Later in the conversation, defendant Sang-Hyun Park stated thatthe price for a real driver’s license was approximately $3,000and this price was not negotiable because he did not make thedriver’s license himself. Defendant Sang H. Park advised theUndercover Agent not to drive with the counterfeit driver’slicense because the counterfeit driver’s license could not begiven to the police. Rather, defendant Sang H. Park explainedthat the purpose of the counterfeit driver’s license was to openbank accounts. Defendant Sang-Hyun Park recounted that in thepast an average customer who invested $7,000 to $10,000 got back approximately $100,000; however, currently, his customers arehaving trouble obtaining $50,000 because of the economy andbecause the banks are unpredictable. Defendant Sang-Hyun Parkfurther stated he uses kkang to obtain money, whereby he requestsothers to swipe credit cards and pays them a kkang fee.

Later during this conversation with the Undercover Agent,defendant Sang-Hyun Park directed defendant Dong-Il Kim to showhis driver’s licenses to the Undercover Agent. According to theUndercover Agent, defendant Dong-Il Kim opened his wallet andtook out two California driver’s licenses. Defendant Sang-HyunPark told the Undercover Agent that one driver’s license was realand one was fake. Defendant Sang-Hyun Park then asked the

42

Undercover Agent for two passport photographs (to make acounterfeit driver’s license) and $7,000 in cash.

b. Thereafter, defendant Sang-Hyun Park directed theUndercover Agent to sit down with defendant Hyun-Jin LNU. Defendant Sang-Hyun Park said to Hyun-Jin LNU: “Make a file, get[the Undercover Agent’s] real name, contact number, and take$7,000 cash.” The Undercover Agent then handed defendant Hyun-Jin LNU approximately $7,000 in cash. In exchange, defendantHyun-Jin LNU provided the Undercover Agent with a receipt for$7,000 that stated: “This is a confirmation that [UndercoverAgent’s assumed name] gave $7,000 payment, dated 5/7/10” andsigned “Jay” [defendant Hyun Jin LNU].

c. In or about July 14, 2010, the Undercover Agentmet defendant Hyun-Jin LNU at a location in Bergen County, NewJersey. During this consensually recorded meeting (audio),defendant Hyun-Jin LNU showed the Undercover Agent a counterfeitNew York driver’s license in the name of “D.M.L.,” in a Chinesename (that was later determined to correspond to a 586 socialsecurity number). Defendant Hyun-Jin LNU gave the UndercoverAgent a business card to a phone company and instructed theUndercover Agent to obtain a cellular phone in the name of D.M.L. In addition, defendant Hyun-Jin LNU stated that they started thebuild up of credit related to this name, and she expected the build up of credit to be completed by mid-August 2010. Thereafter, defendant Hyun-Jin LNU advised the Undercover Agentthat he/she would need to open bank accounts with the falseidentity, telling the Undercover Agent that he/she “needed toforget your [real] name.” Defendant Hyun-Jin LNU stated that“these people [referring to past customers] have done it beforeso [defendant Hyun-Jin LNU and co-conspirators] have a senseabout which places they will be able to pull money out of.” Defendant Hyun-Jin LNU further advised the Undercover Agent afterhe/she obtained money through the scheme that defendant Hyun-JinLNU would take back the identity documents from the UndercoverAgent and destroy them. Defendant Hyun-Jin LNU then told theUndercover Agent: “Listen, you gave me $7,000 . . . . for that,build up, social, and driver’s license are all included. . . . Ifyou get unlucky and get caught somewhere, the easiest thing to doat that time is . . . . [to] just say that a Chinese person in[] Chinatown . . . . say you went to visit Chinatown and metsomeone and that person gave it to you.”

57. Paragraphs 58 through 113 set forth each defendant’sparticipation with or in the Park Criminal Enterprise to usefraudulently obtained identity documents or counterfeit identitydocuments to commit fraud.

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58. Defendant Hyun-Jin LNU

a. As described in Paragraph 51 above, defendant HyunJin LNU, using the Chinese name Hai Hua Xu and a corresponding586 social security number, obtained an identification card inthat name from the IDMV.

b. From in or about April 2009 through October 2009,defendant Hyun-Jin LNU, using the Chinese identity Hai Hua Xu, acorresponding 586 social security number, the fraudulentlyobtained Illinois identification card, and her prior actualaddress, applied for and received credit cards from Bank ofAmerica, Chase, Citibank, Bloomingdale’s, Macy’s, and Saks FifthAvenue (HSBC). Thereafter, these fraudulently obtained creditcards were used to make some the following charges (“kkang”),among others:

Date ofCharge

Credit Card Amount Description

April 28,2009

Macy’s $2,756.83 Li Nails Plus (acompany controlled bydefendant Sang-HyunPark)

April 30,2009

Bloomingdale’s $3,250.63 Li Nails Plus (acompany controlled bydefendant Sang-HyunPark)

May 12,2009

Macy’s $4,789 Mono Corp. (a companycontrolled bydefendant Sang-HyunPark)

c. The charges on the Macy’s credit card were notpaid, resulting in a loss of approximately $8,000. The chargeson the Bloomingdale’s credit card were not paid, resulting in aloss of approximately $5,600. The charges on the HSBC Saks FifthAvenue credit card were not paid, resulting in a loss ofapproximately $12,000.

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59. Defendant Dong-Il Kim

a. As described in Paragraph 51 above, defendant Dongil Kim, using the Chinese name Zhankun Liu and a corresponding586 social security number, fraudulently obtained a driver’slicense in that name from the IDMV. Defendant Dong-Il Kim, usingthe Chinese name Cai Juan Zhang and a corresponding 586 socialsecurity number, fraudulently obtained a driver’s license in thatname from the CDMV.

b. Beginning in or about November 2009, defendantDong-Il Kim, using the Chinese name Zhankun Liu, a corresponding586 social security number, and the fraudulently obtainedIllinois driver’s license that he had obtained, applied for andobtained credit cards issued by TD Bank, Bloomingdale’s andCitibank in the name of Zhankun Liu. Thereafter, thesefraudulently acquired credit card were used to make the following fraudulent charges (“kkang”), among others:

Date ofCharge

CreditCard

Amount Description

November24, 2009

Citibank $5,000 cash advance

November25, 2009

Citibank $700 Hwangini (a companyowned and controlledby Sang-Kyu Seo)

December2, 2009

Citibank $2,685 Erins Supply

December5, 2009

Citibank $1,890 New M and K Global

December6, 2009

Citibank $1,000 Hwangini (a companyowned and controlledby Sang-Kyu Seo)

December9, 2009

TD Bank $1,520 New M and K Global

December10, 2009

TD Bank $1,310 Sunny Enterprise (a company owned andcontrolled byDefendant Hyeon-U Kim)

January 6,2010

TD Bank $500 Hwangini (a companyowned and controlledby Sang-Kyu Seo)

Date ofCharge

CreditCard

Amount Description

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January22, 2010

TD Bank $1,896.97 Li Nails Plus (acompany controlled bydefendant Sang-HyunPark)

60. Defendant Sung-Sil Joh

a. As described in Paragraph 51 above, defendantSung–Sil Joh, using the Chinese name Zhanhong Fan and acorresponding 586 social security number, fraudulently obtainedan identification card in that name from the IDMV.

b. In or about April 10, 2009, an individual usingthe Chinese name Zhanhong Fan and a corresponding 586 socialsecurity number applied for and obtained Visa credit cards issuedby Bloomingdale’s and Macy’s. Based on this investigation, YourAffiant believes that defendant Sung-Sil Joh is the individualwho obtained these credit cards using the Chinese name ZhanhongFan with the corresponding 586 social security number.Thereafter, these fraudulently acquired credit cards were used tomake the following fraudulent credit card charges (both “kkang”and purchases at retail stores):

Date of Charge/Credit Card

Amount Description

April 10, 2009Bloomingdale’s

$3,909.59 Li Nails Plus (a companycontrolled by defendantSang-Hyun Park)

April 17, 2009Macy’s

$3,520.67 Li Nails Plus (a companycontrolled by defendantSang-Hyun Park)

May 1, 2009Bloomingdale’s(store credit)

$6,800 diamond jewelry

June 19, 2009Bloomingdale’s

$5,625 For Your Joy (a company owned andcontrolled by FNU LNU#1,a/k/a “FNU Choi,” “XijunGu”)

June 19, 2009Bloomingdale’s

$500 New M and K Global

Date of Charge/Credit Card

Amount Description

46

June 20, 2009Macy’s

$3,250.79 Erins Supply (a company owned andcontrolled by defendantJung-Hyuck Seo and anemployee of defendantSung-Sil Joh)

June 20, 2009

Macy’s

$2,500 Cocoxu Corp. (defendant Sang-HyunPark’s company)

c. According to Macy’s, the above charges and otherswere not paid, resulting in a loss of approximately $12,500. According to Bloomingdale’s, the above charges and others werenot paid, resulting in a loss of approximately $25,000.

d. On or about June 17, 2009, a telephone payment, inthe amount of $2,760.62, was made against the Bloomingdale’sstore credit card issued in the name of defendant Sung-Sil Joh’sChinese identity Zhanhong Fan with a corresponding 586 socialsecurity number. On or about June 19, 2009, this credit card wasused to purchase a Louis Vuitton item in the amount $1,670 and aFerragamo item for $452 at a Bloomingdale’s store in New York. On or about June 24, 2009, the $2,760.62 telephone payment wasreturned for insufficient funds.

61. Joong-Hyun Jung (see Paragraphs 72m, 84e, and 96).

62. Osung Kwon (see Paragraphs 81i, 84d, 85q, 94q, 95a, and96).

63. Defendant Jin LNU

Use of Fraudulently Obtained Identity Document

a. As described in Paragraph 51 above, defendant JinLNU, using the Chinese name Zhaofang Chen and a corresponding 586social security number, fraudulently obtained an identificationcard and a driver’s license in that name from the IDMV. Defendant Jin LNU Lee, using the Chinese name Jianxin Jiang and acorresponding 586 social security number, fraudulently obtainedan identification card in that name from the IDMV.

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b. In or about December 2008, according to recordsfrom Chase Manhattan Bank, TD Bank, Target and National Bank,defendant Jin LNU, using the Chinese name of Zhaofang Chen, acorresponding 586 social security number, and the fraudulentlyobtained Illinois driver’s license that he had obtained, appliedfor and received credit cards from these credit card companies. Numerous charges were made on each credit card but were not paid,resulting in a loss of approximately $5,000.

The Check-Kiting Scheme

c. On or about November 4, 2009, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Seung-Ho Noh. During this interceptedconversation, they discussed check-kiting:

Noh: I was going to do a few bank[s] for someone .. . . PNC is asking for a passport to open anaccount.

Park: Yes.Noh: You said to open like five, right?Park: Which banks did you open so far?Noh: Citi . . . . TD. . . . Chase. . . . BOA. . .

. Then, that’s four. The other place can beany place like maybe HSBC?

Park: Yes. HSBC is okay, big brother. . . . When Itried recently, my customer just started one. . . . [the customer] was able to take out$20,000 from BOA.

Noh: Oh, really?Park: Yes. It looks like [we] can get about

$15,000 to $20,000 per bank.Noh: Oh, [I] just need to do checking and savings,

right?Park: Yes, and the corporate [account] too.

* * * *

Park: If [I] take out $20,000, I give $10,000 tothe customer and take $10,000 as a processingfee.

* * * *

Noh: How much do you usually get from one bank? If you open it like . . . . about $20,000?

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Park: In my opinion, there shouldn’t be a problemtaking out about $20,000 from one bank. . . .. [f]rom each account.

Noh: Then . . . if one person can take . . . about$50,000.

Park: Our method is a little different from otherbrokers.

Noh: Oh, really?Park: Yes, that’s why [we] are able to take out a

lot. The others [brokers] can take out about$8,000 , but that’s about it.

d. On or about August 4, 2009, according to recordsfrom Capital One Bank and photographs from the bank’ssurveillance video, defendant Jin LNU entered a bank branch inFlushing, New York and opened a checking account in the name ofZhaofang Chen, a Chinese name, using a genuine but fraudulentlyobtained Illinois driver’s license in that name, and acorresponding 586 social security number. In addition, accordingto bank records, defendant Jin LNU also opened a checking accountat the Bank of America in the name of Zhaofang Chen.

e. On or about September 10, 2009, in furtherance ofa check-kiting scheme, a $500 check, drawn on the Bank of Americachecking account of Zhaofang Chen (an identity obtained and usedby defendant Jin LNU), was deposited into a bank account, in thename of Deshang Zhang (an identity obtained and used by defendantHyeon-U Kim), at Flushing Savings Bank, Flushing, New York. (seeParagraph 63f below for transactions between the Desang Zhang andan account in the Y.L. Identity).

f. On or about September 22, 2009, in furtherance ofa check-kiting scheme, defendant Jin LNU caused three checks,each in the amount of $1,000, payable to Y.L. [the Chineseidentity purchased by Cooperating Witness One from defendantSang-Hyun Park], and drawn on the Flushing Savings Account ofDeshang Zhang [defendant Hyeon-U Kim], to be deposited into threedifferent bank accounts opened in the name of Y.L.

g. On or about September 24, 2009, in furtherance ofa check-kiting scheme, a check, drawn on the Capital One Bankaccount of Zhaofang Chen and in the amount of $4,200, wasdeposited into a bank account in the name of Y.L. [CooperatingWitness One]. This check was returned for insufficient funds.

h. On or about September 25, 2009, a check, drawn onthe Capital One Bank account of Zhaofang Chen [a Chinese identityused by defendant Jin LNU] and in the amount of $5,200, was

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deposited into a bank account in the name of Y.L. [CooperatingWitness One]. This check was returned for insufficient funds.

i. On or about September 25, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received in incomingtelephone call from defendant Jin LNU. During this interceptedconversation, they discussed kiting checks through accountsopened in the name of Y.L. [Cooperating Witness One]. Thefollowing discussion ensued, in substance and in part:

Jin LNU: There is some sort of a problem with [Y.L.account]. . . . There is some problem with[Y.L.].

Park: Why?Jin LNU: Well, it keeps getting pending [meaning money

cannot be withdrawn from the account].Park: Oh, what does internet banking show?Jin LNU: Oh, it says $900 is available. And $4,200 is

in pending. $4,300 is in pending.Park: Is that so? Then since tomorrow is Saturday.

Does it change on a Saturday?Jin LNU: Yes. The problem is how many days the check

stays alive [i.e., a reference to the“float”]. So later, big brother, [deposit]one more check. (emphasis added).

Park: Um.Jin LNU: There is one for $5,200 and $5200.

* * * *

Park: It is $5,600 for the 26th.Jin LNU: Yes. . . . Yes, yes. It doesn’t matter if

you switch them before depositing. Depositit today, big brother. Once the money iscollected, they will go around anyways. AndI have to meet this guy and go to the bank.It worked for this guy. . . . . And this guy[Cooperating Witness One], I will call himand meet him.

Park: Okay.

j. On or about September 25, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from defendant Jin LNU. During this interceptedconversation, the following discussion ensued, in substance andin part:

50

Jin LNU: Let me ask you something. . . . [CooperatingWitness One’s Chinese identity, Y.L.’s] PNCBank.

Park: Who, which?Jin LNU: [Y.L.’s] PNC Bank.Park: Yes.Jin LNU: The money should be available as cash in one

or two days . . . . [b]ut when I checked atthe bank, the person who did the deposit . .. . I think a woman did it. [She] didn’tsign the [deposit slip]. And the money istied, now. We have to unlock it.

* * * *

Jin LNU: Yes, yes, so, now I can’t check up, bigbrother. [Cooperating Witness One] . . . has to go and confirm it or phone in andunlock it. . . .

Park: Then, who deposited it? Was it [defendantDong-Il Kim]?

Jin LNU: Is there a woman? The hand writing was awoman’s.

Park: The hand writing, Hyun-Jin LNU [defendantHyun-Jin LNU] wrote it on the deposit slip.

64. Min-Soo Son (see Paragraphs 72c and 95b).

65. Defendant Young-Hee Ju

a. As described in Paragraph 51 above, defendantYoung-Hee Ju, using the Chinese name Mingji Piao and acorresponding 586 social security number, fraudulently obtained adriver’s license in that name from the IDMV.

b. Beginning in or about December 2007, defendantYoung-Hee Ju, using the Chinese name Mingji Piao, a corresponding586 social number, and the fraudulently obtained Illinoisdriver’s license that she had obtained, applied for and obtainedcredit cards from Bloomingdale’s, GE Money Bank/The Gap, LexusFinancial Savings, and Washington Mutual, among others.

c. From in or about December 2007 through in or aboutAugust 2009, defendant Young-Hee Ju, using a Bloomingdale’scredit card in the name of Mingji Piao, made numerous purchaseswith this card, including clothes, jewelry, make up, sunglasses,and gift cards. These charges, among others, were not paid,resulting in a total loss of approximately $1,600.

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d. In total, Washington Mutual reported a total lossof approximately $36,000, resulting from unpaid charges on thecredit card obtained by defendant Young-Hee Ju in the name ofMingji Piao.

e. On or about January 20, 2009, according to recordsfrom Toyota Motor Credit Corporation, defendant Young-Hee Juapplied for and received a car loan in Bergen County, New Jersey,in the approximate amount of $40,593, from Toyota Motor CreditCorporation to purchase a black, 2009 Lexus SUV. On theapplication, defendant Young-Hee Ju represented that her name was Mingji Piao with a corresponding 586 social security number. Shelisted her employer as Jung Skin Productions. Furthermore, onthis application, defendant Young-Hee Ju used her actual FortLee, New Jersey address and her actual phone number (which numberwas the Ju Target Facility). This loan went into default withintwo months on the purchase of the car. According to records fromToyota Motor Credit Corporation, the company repossessed the car.

f. On or about March 25, 2009, in Palisades Park,New Jersey, federal agents observed defendant Young-Hee Ju meetwith Cooperating Witness Two. During this meeting, defendantYoung-Hee Ju arrived in a black, 2009 Lexus SUV.

g. On or about July 27, 2009, over the Ju TargetFacility, a representative from Toyota Motor Credit Corporationcalled defendant Young-Hee Ju concerning the black, 2009 LexusSUV. During this intercepted conversation, the followingdiscussion (in English) ensued, in substance and in part:

Company: Hello, I’m looking for Ming Pia [MingjiPiao].

Ju: No, you got a wrong number now.Company: Is this Ming Piao?Ju: No.

* * * *

Company: Okay, this is not Ming Piao?Ju: No.Company: Is this Jung Skin Productions?Ju: Yes, Jung Productions, yes.Company: Yeah?Ju: Yes.Company: Okay, so, you drive a Lexus, right?Ju: No, Oh, no, no, no. She’s not home now.

* * * *

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66. Defendant Hyo-Il Song

a. As described in Paragraph 51 above, defendant HyoIl Song, using the Chinese names Yan Hua Wei (IDMV), Minghao Li(TDMV), and Dongyun Zhou (PennDOT) and corresponding 586 socialsecurity numbers, fraudulently obtained driver’s licenses inthose names. In addition, defendant Hyo-Il Song, using theChinese name Haizhe Pei and a corresponding 586 social securitynumber, fraudulently obtained an identification card in that namefrom the IDMV.

b. In or about July 2007, defendant Hyo-Il Song,using the Chinese name identity Yan Hua Wei, a corresponding 586social security number, and the fraudulently obtained Illinoisdriver’s license that he had obtained, applied for and receivedcredit cards from Bank of America (three credit cards), ChaseBank, HSBC, PNC Bank, and Target National Bank.

c. On or about September 6, 2007, defendant Hyo IlSong, using the identity Yan Hua Wei and a corresponding 586social security number, obtained a cash advance, in theapproximate amount of $10,000, by issuing himself a Bank ofAmerica convenience check charged to the Yan Hua Wei Bank ofAmerica credit card. This charge and other charges were notpaid, resulting in a loss of approximately $25,000.

d. On or about July 22, 2008, defendant Hyo IlSong, using the identity Yan Hua Wei and a corresponding 586social security number, made and caused to be made a checkpayment, in the approximate amount of $3,900, to the TargetNational Bank credit card. On or about July 23, 2008, defendantsHyo-Il Song and Sang-Hyun Park, fraudulently chargedapproximately $3,685 to the Target National Bank credit card inthe name of Yan Hua Wei through Ameth Thread. On or about July29, 2008, defendants Hyo-Il Song and Sang-Hyun Park, fraudulentlycharged approximately $3,590 to the Target National Bank creditcard in the name of Yan Hua Wei through Mono Corp. These chargesand other charges were not paid, resulting in a loss ofapproximately $11,500 on this credit card.

e. On or about February 4, 2009, according to recordsfrom Toyota Motor Credit Corporation, defendant Hyo-Il Song, applied for and received a car loan in Westchester County, NewYork, in the approximate amount of $55,285 from Toyota MotorCredit Corporation to purchase a grey, 2008 Lexus sedan. In orabout early March 2009, a law enforcement officer observed andvideo recorded defendant Hyo-Il Song driving the same 2008 grayLexus sedan, bearing a New York license plate. Furthermore,

53

according to records from the New York Department of MotorVehicles, this car was registered in the name of Minghao Li. This same 2008 gray Lexus sedan was observed parked in thedriveway of defendant Hyo-Il Song’s residence in Palisades Park,New Jersey. According to records from the finance company, theloan defaulted. Before this loan defaulted, according to recordsfrom the finance company, two payments were received: (1) acheck, drawn on the account of 90 You & Me, in the amount of$948.94; and (2) a check, drawn on the account of 90 You & Me, inthe amount of $948.94. Defendant Hyo-Il Song controlled the bankaccount of 90 You and Me. This car was repossessed.

f. Beginning in or about early May 2009, defendantHyo-Il Song, using the Chinese name Haizhe Pei and acorresponding 586 social security number, applied for andreceived credit cards from HSBC Saks Fifth Avenue, HSBC NeimanMarcus, Nordstrom, Macy’s, and Bloomingdale’s.

g. In or about early March 2009, a law enforcementofficer observed and video recorded defendant Hyo-Il Song drivinga 2005 Lexus SUV with a New Jersey license plate. According torecords from the New Jersey Department of Motor Vehicles, thiscar was registered in the name of Haizhe Pei. Furthermore, thissame car was observed parked in the driveway of defendant Hyo-IlSong’s residence in Palisades Park, New Jersey.

h. On or about October 1, 2009, the HSBC Saks FifthAvenue credit card defendant Hyo-Il Song obtained using theHaizhe Pei identity was used to purchase a $12,350.48 watch froma Saks Fifth Avenue retail store, in Bergen County, New Jersey. HSBC Saks Fifth Avenue never received payment for this purchaseand, in total, sustained approximately $16,000 in loss on thiscredit card.

i. On or about March 9, 2010, defendant Hyo-Il Song,using the Chinese name Dongyun Zhou and a corresponding 586social security number, made a check, payable to Bloomingdale’sVisa, in the approximate amount of $4,390. On or about March 10,2010, a charge in the amount of approximately $4,650 was made at90 You and Me, defendant Hyo-Il Song’s company. The checkpayment in the amount of $4,390 was later returned forinsufficient funds.

j. As described in Paragraph 107 below, defendantHyo-Il Song was a collusive merchant.

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67. Defendant Dong-Won Kim

a. As described in Paragraph 51 above, defendant DongW. Kim, using the Chinese names Guangying Zhang, Huaying Lu, andWei Yun Zhong and corresponding 586 social security numbers,fraudulently obtained one identification card and three driver’slicenses in those names from the IDMV.

b. On or about August 29, 2008, according to recordsfrom Toyota Motor Credit Corporation, defendant Dong-Won Kim, applied for and received a car lease in Westchester County, NewYork, in the approximate amount of $46,000 (the value of the car)from Toyota Motor Credit Corporation to lease a black, 2008 LexusSUV. On the application, defendant Dong-Won Kim represented thathis name was Guangying Zhang with a corresponding 586 socialsecurity number. Furthermore, on this application, defendantDong-Won Kim used his actual New York address and provide an HSBCcredit card in the name of Guangying Zhang and a Chase bankstatement in the same name. This lease went into default in orabout January 2009. According to records from Toyota MotorCredit Corporation, it has been unable to repossess this vehiclebecause it cannot be located.

c. On or about September 8, 2009, over the First ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant Dong-Won Kim. During this interceptedconversation, the following discussion ensued, in substance andin part:

Park: Did you sell the car. The Lexus?Kim: No, not yet.Park: Why? Did you decide not to give it to that

guy?Kim: It’s not that. They were going to give only

$1,500.Park: . . . . They will give you up to 15% of the

vehicle’s market value.Kim: Without anything? . . . . There is nothing, I

am telling you. . . . Expired registration,no insurance, no title.

Park: Needs to go to China, China. . . . Thebastard in Dallas. The dude collects wholebunch of cars and sends them to China.

* * * *

Park: He went around Georgia, Dallas, Texas and nowhe is in LA [Los Angeles]. He is the one who

55

could get a driver’s license without the testat $5,000. I did that once in the past. Hedoes a lot of stuff going all over thecountry. He knows a lot of sources. . . .There are a ton of people who can’t make carpayments in LA, right?

Kim: Right.Park: There are lots cars [sic] like that in New

York and [he] asked to collect them. Willgive up to 15% . . . .[f]or $40,000, it’s agood amount. It’s better than giving [thecar] away at $1,500-$2,000.

Kim: Right.Park: We will get together when he comes.

d. In or about August 2008, defendant Dong-Won Kim,using the Chinese name Guangying Zhang and a corresponding 586social security number, applied for and obtained credit cardsfrom American Express, Chase Bank (three credit cards), Citibank,Bloomingdale’s, Macy’s, and HSBC Bank.

e. On or about September 25, 2008, defendant Dong W.Kim, using a Bloomindale’s credit card in the name of GuangyingZhang, purchased, and caused to be purchased, Louis Vuittonmerchandise in the approximate amount of $750. On or aboutOctober 7, 2008, defendant Dong-Won Kim, using a Macy’s creditcard in the name of Guangying Zhang, purchased, and caused to bepurchased, Ferragamo merchandise in the approximate amount of$1,430. These charge were not paid.

f. On or about October 22, 2008, a check, in theamount of $10,400, was transmitted to HSBC credit card forpayment of charges on the credit account of Guangying Zhang. Onor about October 27, 2008, this payment was returned forinsufficient funds. Before this payment was returned forinsufficient funds, the following fraudulent charges were made onthis credit card:

g. On or about October 24, 2008, defendants DongW. Kim and Sang-Hyun Park fraudulently charged approximately$5,325 to an HSBC credit card in the name of Guangying Zhangthrough Mono Corp. (a company controlled by defendant Sang-HyunPark).

56

h. On or about October 25, 2008, defendants DongW. Kim and Sang-Hyun Park fraudulently charged approximately$2,920 to an HSBC credit card in the name of Guangying Zhangthrough Ameth Thread a company controlled by defendant Sang-HyunPark).

i. In addition, as described in Paragraph 50 above,defendant Dong-Won Kim was a broker of 586 social security cardsand driver’s licenses.

68. Defendant Seung-Ho Noh (defendant Seung-Ho Noh was abroker of 586 social security cards, counterfeit driver’slicenses, and used these 586 social security numbers to commit avariety of frauds, including “check jobs” (check-kiting) and “taxwork” (tax fraud).

69. Defendant Matthew J. Kang (as described in Paragraphs13 above and 102 below, defendant Matthew J. Kang conspired withthe Park Criminal Enterprise and others to fraudulently buildcredit scores for the purpose of committing fraud).

70. Defendants Rita S. Kim and Hyon-Suk Chung (as describedin Paragraph 103 below, defendants Rita S. Kim and Hyon-Suk Chungconspired with the Park Criminal Enterprise and others tofraudulently build credit scores for the purpose of committingfraud),

71. Defendant Young-Woo Ji (as described in Paragraphs 81and 104 below, defendant Young-Woo Ji conspired with the ParkCriminal Enterprise and others to fraudulently build creditscores for the purpose of committing fraud).

72. Defendants Sang-Kyu Seo and Amy Yang

a. On or about September 21, 2009, over the FirstPark Facility, defendant Sang-Hyun Park made an outgoingtelephone call to defendant Sang-Kyu Seo (the husband ofdefendant Amy Yang). During this intercepted conversation, thefollowing discussion ensued, in substance and in part:

Park: Why did you call, big brother?Seo: What is the status?Park: First, your wife’s, what is it, BOA was

opened? [defendant Sang-Kyu Seo’s wife is defendant Amy Yang, a/k/a “Yulan Qian” and“Amy Pitts”]

Seo: Um, um.

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Park: So we have to wait until build up is done. Build up was started so [we] just need towait until it’s done.

Seo: Mm-mm.Park: And then, when the debit card arrives, the

debit card becomes a second ID, so you takethat to the [bank] and open an account. . . .The reason for that is [that bank] doesn’tapprove cards or loans right after you open abank account. You need transaction history.. . . That’s why, since it takes a month ortwo for the build up, so during that period[we] are opening the account and getting itready.

Seo: Mm-mm.

b. On or about October 3, 2009, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Sang-Kyu Seo. During this interceptedconversation, they discussed “busting out” defendant Sang-KyuSeo’s personal and business credit cards:

Park: What about business cards?Seo: In the case of business cards, they also

almost full [charged to the maximum creditamount]. I have three $12,000 one[s]. Atfirst, they gave me $20,000 but reduced to$12,000. . . . Corporate ones are also full.

* * * *Park: Then, if you are considering doing it, we can

do it only once for Chase. What it means. .. . we can take out up to the limit.

Seo: Yes, yes.Park: Yes. In the case of Chase, to make cash, we

have to purchase merchandise and resell them[sic].

Seo: Uh, it means I have to buy something with it?Park: Yes. You have to buy something because if we

swipe [i.e., charge] the card with merchant,to be frank, to make cash, or after I check[the] statement and if it is okay, you cantake cash out from the casino.

Seo: Yes, yes.

* * * *

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Seo: Is it legitimate? Park: Yes, there is no problem. Yes, I am doing it

because there is no problem. But, you haveto expect your credit score will be dropped.

Seo: Of course. . . .Park: You know it. If you don’t pay for the debt,

the score becomes bad.Seo: That’s right. Anyhow, it was already

dropped.

* * * *

Park: And then, you don’t have to worry about ifsomeone will come from a bank.

Seo: Yes, yes. Anyway, later . . . . I willdeclare Chapter 7 or Chapter 13 bankruptcy.

c. In furtherance of the scheme to “bust out”defendant Sang-Kyu Seo’s personal credit cards, on or aboutDecember 18, 2009, defendant Min-Soo Son entered a Bank ofAmerica branch in Fort Lee, New Jersey and made a payment, in theform of a check drawn on the account of Erins Skin Care, Inc., inthe amount of $18,462, toward defendant Sang-Kyu Seo’s Bank ofAmerica credit card. On or about December 21, 2009, this checkwas returned for insufficient funds. On or about December 18,2009, the Bank of America received a telephone inquiry, from aphone number used by defendant Sang-Hyun Park, checking on thestatus of defendant Sang-Kyu Seo’s Bank of America credit card.

d. The Bank of America reported a loss ofapproximately $75,000 on this credit card. Furthermore,according to Bank of America, a second credit card issued todefendant Sang-Kyu Seo resulted in a loss of approximately$11,500. Before the credit card was “busted out,” a fraudulentcharge, in the approximate amount of $4,899, was made on thiscredit card to Li Nails Plus.

e. On or about December 22, 2009, according torecords from HSBC Bank, defendant Sang-Kyu Seo maintained abusiness line of credit in the name of Pier 7 Corporation. On orabout December 22, 2009, this line of credit had been drawn downto a $0 available balance. On that day, in Los Angeles,California, a $47,000 check was deposited into the Pier 7Corporation line of credit account belonging to defendant Sang-Kyu Seo thereby increasing the available credit to approximately$47,000. This check was later returned for insufficient funds.

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f. On or about December 24, 2009, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Sang-Kyu Seo. During this interceptedconversation, defendant Sang-Kyu Seo stated that he took outapproximately $20,000 in cash from an HSBC checking account. Defendant Sang-Kyu Seo then advised that the balance, ofapproximately $27,000, was transferred to a checking account.

g. On or about December 24, 2009, defendant Sang KyuSeo issued a check, drawn on this Pier 7 Corporation line ofcredit, in the amount of $27,000 and deposited it into a HSBCbusiness checking account in his name.

h. On or about December 24, 2009, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Sang-Kyu Seo. The following conversationensured, in substance and in part:

Park: Well, now the problem is you took out themoney from the bank because you deposited acheck you received from somebody and thecheck [funds] has become available.

Seo: Yes, yes.Park: The bank employee was not stupid to give you

the money when there was no money availablein the account, was he/she?

Seo: Uh, uh, uh.Park: Therefore, what you should do is this: You

are the party that received the money, bigbro. Right?

Seo: That is right.Park: Yes, you received the money and because the

money was cleared at the bank, and “I” [sic]confirmed with the bank in the morning andtook out the money. . . . [s]o, franklyspeaking between us, when we speak openlybetween us, it is not that we deposited acheck that will bounce. . . .

i. On or about December 29, 2009, over the First ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant Sang-Kyu Seo. During this interceptedconversation, defendant Sang-Hyun Park asked if defendant Sang-Kyu Seo if he was coming to defendant Sang-Hyun Park’s office togive him his fee. Defendant Sang-Kyu Seo stated, “I told you towait two, three days for that.” Defendant Sang-Hyun Parkresponded, “What’s there to wait? Those [co-conspirators] in LAare going crazy over it [their fee].”

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j. On or about December 31, 2009 and on or aboutJanuary 5, 2010, defendant Sang-Kyu Seo issued two checks, toCiti Apparel, in the approximate amounts of $4,950 and $4,800,respectively. These two checks were endorsed by defendant Hyun-Jin LNU (using the name Hai Hua Xu) and deposited into the CitiApparel account.

k. In total, defendants Sang-Kyu Seo and his co-conspirators fraudulently obtained in excess of $100,000 by“busting out” business and personal credits cards and lines ofcredit.

l. From in or about February 2010 through in or aboutApril 2010, defendant Amy Yang, using the identity Yulan Qian anda corresponding 586 social security number, obtainedapproximately two credit cards from Target National Bank andChase Bank, resulting in a loss of approximately $3,000. Inaddition, defendant Amy Yang “busted out” credit cards in hername through defendant Sang-Hyun Park and his co-conspirators,resulting in losses totaling approximately $120,000 to severalcredit card companies.

m. On or about June 30, 2010, according to recordsfrom Valley National Bank and photographs from the bank’ssurveillance video, defendant Amy Yang [defendant Sang-Kyu Seo’swife] entered a Valley National Bank in Bergen County and openedan account in the name of Yulan Qian, a Chinese name, acounterfeit Nevada driver’s license, and a corresponding 586social security number (which social security number was notissued to defendant Amy Yang by the United States). Furthermore,photographs from the bank’s surveillance video reveals thatdefendant Joong-Hyun Jung accompanied defendant Amy Yang into thebank. On the application to open the account, defendant AmyYang, using the name Yulan Qian, listed her actual home addressin Palisades Park, New Jersey (where a law enforcement officer,while conducting surveillance, observed defendant Amy Yang enterand exit).

n. As described in Paragraph 53u above, defendantSang-Kyu Seo was a collusive merchant.

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73. Defendant Hyun-Yop Sung

a. As described in Paragraph 51 above, defendantHyun-Yop Sung, using the Chinese name Shanji Li and acorresponding 586 social security number, fraudulently obtained adriver’s license in that name from the IDMV.

b. Beginning in or about March 2009, according torecords from PNC, Chase Bank, Capital One, and credit reportingagency, defendant Hyun-Yop Sung, using the Chinese name ShanjiLi, a corresponding 586 social security number, the fraudulentlyobtained Illinois driver’s license he had obtained, and anaddress belonging to defendant Hyun-Yop Sung in Carlstadt, NewJersey, applied for and received several credit cards in the nameof Shanji Li.

c. Numerous charges were made on the credit cardsissued in the name of Shanji Li that were not paid, resulting ina loss of approximately $30,000.

74. Defendant FNU LNU#1, a/k/a “Mr. Choi” and “Xijun Gu”

a. As described in Paragraph 51 above, defendant FNULNU#1, using the Chinese name Xijun Gu and a corresponding 586social security number, fraudulently obtained a driver’s licensein that name from the IDMV.

b. In or about March 2009, according torecords from various credit card companies and a credit reportingagency, defendant FNU LNU#1, using the Chinese name Xijun Gu, acorresponding 586 social security number, the fraudulentlyobtained Illinois driver’s license that he had obtained, and anaddress belonging to defendant FNU LUN#1, applied for andreceived approximately 9 credit cards from Bank of America,Macy’s, Bloomingdale’s, Saks Fifth Avenue, Nordstrom, TargetNational Bank, and GE Money Bank. Numerous charges were made oneach credit card but were not paid, resulting in a loss ofapproximately $30,000.

c. On or about September 8, 2009, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant FNU LNU#1, a/k/a “Mr. Choi” and “Xijun Gu.” During this intercepted conversation, defendant FNU LNU#1complained about extensive delays concerning another customer’scredit build up. Defendant Sang-Hyun Park responded that thecredit build ups being done by Shin Hwa [defendants Rita S. Kimand Hyon-Suk Chung] are being delayed “not just yours, but minealso.” Furthermore during this conversation, defendant Sang-Hyun

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Park stated, “I also after giving it to President Daniel [Hyo-IlSong] before, in the middle . . . so you and I are in the samesituation. . . . In Cheng Yu Ma’s case [see Paragraphs 84e, 89h,and 96 below], the address is not verified so we cannot do anywork.” Later during that conversation, defendant Sang-Hyun Parkstated that he verified the address for Cheng Yu Ma through acredit report agency, and he planned to make two credit cardswith this information. Defendant FNU LNU#1 stated, “Exactly.”

d. On or about September 11, 2009, a Target NationalBank credit card issued in the name of Xijun Gu was charged byStar 72 Jewelry in the amount of approximately $2,739.

e. On or about September 14, 2009, over the FirstPark Facility, defendant Sang-Hyun Park made an outgoingtelephone call to defendant FNU LNU#1, a/k/a “Mr. Choi” and“Xijun Gu.” During this intercepted conversation, defendant FNULNU#1 stated that a representative of Citibank told him that themerchant “was a bad merchant,” to which defendant Sang-Hyun Parkreplied, “With Citi you can never use our [credit card] machine.. . . the reason is they have the old record of our second work[the second round of “bust outs”], you see? So, you need to waitat least six months before you do the swipe. . . . You shouldremember, with Citi, when you do the swipe one after another thecardholder as well as the merchant get in trouble.” DefendantFNU LNU#1 replied, “And the company gets on the black list.” Later in the conversation, defendant FNU LNU#1 stated that afterbuilding credit that one could take approximately $30,000 fromthe bank and added: “It never failed. We always got money fromthe bank.”

f. On or about September 23, 2009, a Bloomingdale’scredit card issued in the name of Xijun Gu was charged by Star 72Jewelry in the amount of approximately $3,865. On or aboutOctober 10, 2009, this same credit card was charged by Lu 72Fashion, Inc. in the amount of approximately $4,190. On or aboutOctober 14, 2009, this same card was charged by Cocoxu in theamount of approximately $200. On or about October 8, 2009, atelephone payment in the amount of approximately $4,214 was madetoward this credit card. On or about October 16, 2009, thispayment was returned for insufficient funds.

g. On or about October 13, 2009, according to recordsfrom Nordstrom and phone records, a telephone inquiry (not oneither the First Park Facility or the Second Park Facility) froma telephone used by defendant Sang-Hyun Park was made toNordstrom, checking on available credit related to the creditcard account of Xijun Gu.

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h. On or about April 14, 2009, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant FNU LNU#1, a/k/a “Mr. Choi” and “Xijun Gu.” During this intercepted conversation, defendant Sang-Hyun Parkasked, “Were you making passports with a local [driver’slicense]?,” and defendant FNU LNU#1 replied, “I have been[making] any one of the fifty-one [sic] states, whatever theyordered.” Defendant Sang-Hyun Park then asked, “Were youreplicating a passport book?,” and defendant FNU LNU#1 replied,“Yes, I even replicate the bar code on the back so when you swipeit the number would show up.” Defendant Sang-Hyun Park asked,“Also ID?” Defendant FNU LNU#1 replied, “Yes, yes . . . . NewJersey ID, it looks so real not even a cop can tell.” DefendantFNU LNU#1 stated he was no longer making identifications. Laterduring the conversation, defendant FNU LNU#1 stated that he has“many Korean social [security cards].” When defendant Sang-HyunPark asked if these social security cards were for sale,defendant FNU LNU#1 replied, “I have quite a few Koreans [socialsecurity cards]. My successors will sell and manage them. Ijust want to keep one or two to do the build up once a year formy own.”

i. As described in Paragraph 109 below, defendantFNU LNU#1 was a collusive merchant.

75. Defendant Hyeon-U Kim

a. As described in Paragraph 51 above, defendantHyeon-U Kim, using the Chinese name Deshang Zhang and acorresponding 586 social security number, fraudulently obtainedan identification card in that name from the IDMV. DefendantHyeon-U Kim, using the Chinese name Xiurong Xu and acorresponding 586 social security number, fraudulently obtained adriver’s license in that name from PennDOT.

b. Beginning in or about April 2007, defendant Hyeon-U Kim, using the Chinese name Deshang Zhang, a corresponding 586social security number, and the fraudulently obtained Illinoisdriver’s license that he obtained, applied for and receivedseveral credit cards from Chase Bank and HSBC Bank.

c. Numerous charges were made on these credit cardsand others. For example, from on or about January 9, 2008 thoughJanuary 10, 2008, a Chase credit card was used to obtainapproximately $15,000 in gift cards from various stores in NewJersey. The charges and others on these credit cards were notpaid, resulting in a loss of approximately $50,000.

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d. Beginning in or about April 2008 ,defendant Hyeon-U Kim, using the Chinese name Xiurong Xu, a corresponding 586social security number, and the fraudulently obtainedPennsylvania driver’s license that he obtained, applied for andreceived several credit cards from Chase Bank, Capital One, HSBCBank/Best Buy, and Macy’s. Based on this investigation, YourAffiant believes that defendant Hyeon-U Kim is the individual whoobtained these credit cards using the Chinese name Xiurong Xuwith the corresponding 586 social security number.

e. Numerous charges were made on each credit card. The charges on these credit cards were not paid, resulting in aloss of approximately $8,000.

f. As described in Paragraph 106 below, defendantHyeon-U Kim was a collusive merchant.

76. Defendant Edward M. Ha (as described below in Paragraph108, defendant Edward M. Ha was a collusive merchant).

77. Defendant Jong-Hoon Kim

a. As described in Paragraph 51 above, defendantJong-Hoon Kim, using the Chinese name Zhengshu An and acorresponding 586 social security number, fraudulently obtainedan identification card and a driver’s license in that name fromthe IDMV. In addition, defendant Defendant Jong-Hoon Kim, usingthe Chinese names Ruiping Chen and Chun Shi Huang andcorresponding social security numbers, fraudulently obtainedidentification cards in those name from the IDMV.

b. On or about May 19, 2009, defendant Jong-Hoon Kim,using the Chinese identity Zhengshu An and a corresponding 586social security number, applied for and received a credit cardmachine under the business name Red Coco Int’l from a merchantbank. On this application, defendant Jong-Hoon Kim reported thatthis company was engaged on the business of wholesale seafood andgrocery distribution; he listed the business’ credit card salesas $30,000 per month; and he used his actual address, anapartment in Ridgefield Park, New Jersey. During thisinvestigation, a law enforcement officer conducting surveillancenear this premises, observed and video recorded defendant Jong-Hoon Kim exiting this apartment. Furthermore, on thisapplication, defendant Jong-Hoon Kim provided checking accountinformation, namely, a TD Bank account in the name Red CocoInt’l, so the proceeds of credit card transactions could bedeposited into this account.

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c. During this investigation, it was determined thatdefendant Jong-Hoon Kim applied for and received additionalcredit card machines from other merchant banks.

d. On or about September 28, 2009, over the FirstPark Facility, defendant Jong-Hoon Kim. During this interceptedconversation, the following discussion ensued, in substance andin part:

Kim: Someone wants to do a card. How should I dothis? What items do you need?

Park: Same as before. . . . Write down all theinformation. And license copy and social andthe rest, card and statement.

* * * *Kim: How many percent?Park: It is 50. 50 to the customer.Kim: So after discount, the cash given is 50,

right?Park: Yes, yes. 50. Yes.Kim: . . . . In the half and half, you and I will

share, right?Park: Yes, yes. It’s the same. Nothing changed,

big brother. Okay?

e. On or about November 6, 2009, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Jong-Hoon Kim. During this interceptedconversation, the following discussion ensued, in substance andin part:

Kim: Anyway, I heard that you are doing some ofthe 586 work these days.

Park: Oh. [Laughs]. 586?Kim: Well, you change the license[s], there was a

such thing since a long time ago. Can you doit fine?

Park: What thing, what thing?Kim: You know there is a thing like opening a 586

account and pull out. . . .Park: [cutting off Kim] Oh, you mean the check

work? [a reference to kiting checks to commitbank fraud].

Kim: YeahPark: Oh. That, I am doing that steadily. . . . .

I am still doing that. . . .

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* * * *

Kim: . . . . I sure, sure you have a lot of [5]86syou have already done.

Park: With that, I pulled $20,000 out per account.Kim: Wow, you did well!Park: Yes, I am doing that . . . quietly. I don’t

let others know.

* * * *

Kim: If you get $20,000, how much do you take? You probably take half off [of] $20,000, doyou?

Park Yes, we charge 50%.Kim: That’s not bad. Hey, can I use [the] 586

that I have? You know I have some too.Park: I can’t do yours because we have too many.Kim: Why?Park: You think about it? How many do you think we

opened altogether per each social number[sic] for people who have 586? We opened atleast three to four [accounts]. . . . Thetime it takes for us to open is not just oneor two days, but it takes one month. . . . .[T]o do the work and pull money. . . . So, ifseveral tens of people, not just one or two,bring it, it amount[s] to 30 [accounts] ofthem when we do three for each person evenfor 10 people. . . . Besides, you have toopen so many bank books too. . . . Then, whenwe have to manage them one month on our side,we need so many people. . . . One person canmanage only three to four accounts. . . . Ihave to have tens of employees to do that. .. .

* * * *

Park: [B]ut if you have 586 customer, give them tome for social or something.

Kim: . . . . I can give you the social number[sic] and bank account that is opened then. .. . How much does that get paid? Does it getpaid about $10,000?

Park: For that too, I get about $7,000 andcustomers can take about $3,000 per onesocial number [sic].

Kim: Oh, for each one?Park: Yes.

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e. In addition, as described in Paragraph 89 below,defendant Jong-Hoon Kim conspired with defendants Sang-Hyun Park,Hag-Sang Jang, and others to “bust out” Hag-Sang Jang’s personaland business credit cards.

78. Defendant Chi-Won Jeon

a. As described in Paragraph 51 above, defendant ChiWon Jeon, using the Chinese name Xianzi Luo and a corresponding586 social security number, fraudulently obtained a driver’slicense in that name from the IDMV. Defendant Chi-Won Jeon,using the Chinese name Fengling Jin and a corresponding 586social security number, fraudulently obtained a driver’s licensein that name from the IDMV.

b. Beginning in or about October 2007, defendant ChiWon Jeon, using the Chinese name Xianzi Luo, a corresponding 586social security number, and the fraudulently obtained Illinoisdriver’s license that she had obtained, applied for and receivedlines of credit from Citibank (three lines of credit) and creditcards from Macy’s, Bloomingdale’s, Citibank, Chase Bank, HSBCBank, Neiman Marcus, Saks Fifth Avenue, and Target National Bank. Numerous charges were made on these credit cards that were notpaid, resulting in a loss of approximately $65,000.

c. In or about November 2008, defendant Chi-Won Jeon, using the Chinese name Fengling Jin, a corresponding 586 socialsecurity number, the fraudulently obtained Pennsylvania driver’slicense that she had obtained, and her actual address (asreflected on her New Jersey driver’s license issued in her realname), applied for and received credit cards issued by ChaseBank, PNC Bank, Citibank, Macy’s (Visa credit card and storecredit), and Bloomingdale’s.

d. According to records from Macy’s, a Macy’s storecredit card account, in the name of Fengling Jin, was used topurchase the following items:

Date of Transaction Amount Item Purchased

January 3, 2009 $870 diamond earrings

January 3, 2009 $730 Louis Vutton item

January 8, 2009 $9,077 diamonds

February 20, 2009 $400 electronic gift cards

February 20, 2009 $200 Chanel make up

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e. According to records from Macy’s, on or about onor about February 18, 2009, a check payment in the amount of$1,319.21 was made against this account. On or about March 4,2009, this payment was returned because of insufficient funds. The charges on this credit card were not paid, resulting in aloss of approximately $15,000.

f. According to records from Macy’s, on or aboutFebruary 23, 2009, a charge, in the amount of approximately $20,was made on the Macy’s Visa credit card in the name of FenglingJin. The listed merchant for this charge is 90 You & MeCorporation, a collusive merchant controlled by defendant Hyo-IlSong. This charge was a “test charge” to determine whether ornot the credit card was still active so additional charges (i.e.,“bust outs”) could be made.

g. According to bank and credit card company records,multiple charges were made on the credit cards in the name ofFengling Jin. According to these records, these charges were notpaid, resulting in a loss of approximately $31,000.

h. On or about September 22, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from defendant Chi-Won Jeon. During thisintercepted conversation, defendant Chi-Won Jeon stated, “I wasreferred by Stephanie [defendant Young-Hee Ju] so I called. Ithink I saw you once before. . . . Well, I wanted to go visit youtoday about doing a loan.”

79. Defendant Jung-Hyuck Seo

a. As described in Paragraph 51 above, defendantJung-Hyuck Seo, using the Chinese name Xiaoqin Zhang and acorresponding 586 social security numbers, fraudulently obtainedan identification card in that name from the IDMV.

b. Beginning in or about January 2009, defendantJung-Hyuck Seo, using the Chinese name Xiaoqin Zhang, acorresponding 586 social security number, and the fraudulentlyobtained Illinois identification card that he had obtained,applied for and received credit cards from Chase Bank,Bloomingdale’s, Macy’s, HSBC Bank/Best Buy, HSBC Bank, and PNCBank.

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c. Thereafter, these fraudulently obtained creditcards were used to make the following charges, among others:

Date ofCharge

Credit Card Amount Description

February20, 2009

PNC $7,000 convenience check

April 29,2009

PNC $2,000 convenience check

May 24,2009

Bloomingdale’s $274 clothes

July 23,2009

Macy’s $896 clothes

These charge were not paid and others were not paid, resulting ona loss of approximately $22,000.

d. Beginning in or about early 2008, an individualusing the Chinese name Xiaoqin Zhang, an Illinois identification,and a corresponding 586 social security number, opened a personalchecking account and a business checking account in the name ofErin’s Skin Supply at Washington Mutual (now Chase Bank). According to records from the Erin’s Skin Supply account, inDecember of 2009, the account had a balance of less than $100. Thereafter, approximately nine checks, totaling approximately$84,000 were drawn on this account to others. The bank did notrelease the funds. On the Xiaoqin Zhang personal account,approximately six checks, totaling approximately $46,500 weredrawn on this account. The bank did not release the funds.During this investigation, a law enforcement officer conductedsurveillance near Cello Hair, located in Palisades Park, NewJersey and observed and video-recorded: (i) a sign for “Erin’sMeridian Skincare” above the rear entrance of Cello Hair (whichaddress was used on the bank records to open the Erin’s SkimSupply business account); and (ii) defendant Jung-Hyuck Seoinside Cello Hair on numerous occasions, where he is employed asa hair stylist. In addition, defendant Sung-Sil Joh was alsoobserved and video-recorded inside Cello Hair.

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80. Defendant Jong-Kwan Hong

a. On or about September 9, 2009, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Jong-Kwan Hong. During this interceptedconversation, defendant Jong-Kwan Hong asked, “Do you have anygood news”,” and defendant Sang-Hyun Park replied, “I gave youboth ID and social number [sic].” “Yes, I have both. . . . Andthen I opened at both banks,” replied defendant Jong-Kwan Hong. Defendant Sang-Hyun Park then directed defendant Jong-Kwan Hongto deposit money into the accounts and use the money [to create atransaction history to give the illusion that the account islegitimate].

b. On or about September 14, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from defendant Jong-Kwan Hong. During thisintercepted conversation, defendant Jong-Kwan Hong asked aboutapplying for and obtaining credit cards. Defendant Sang-HyunPark replied, “I am working on the build up. Build up should becomplete. . . . I will be the first one to get the conformation. Just wait, please.” Defendant Jong-Kwan Hong complained, “It’sbeen over two months,” and defendant Sang-Hyun Park replied,“Lately, it takes about three months.”

c. On or about September 18, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from defendant Jong-Kwan Hong. During thisintercepted conversation, defendant Jong-Kwan Hong stated, “I got[the] Bank of America’s check book.” “Bring all of them togetherlater when you come to see me,” replied defendant Sang-Hyun Park. Defendant Jong-Kwan Hong then stated, “For now, I got the checkbooks from both. And I got all the debit cards.”

d. On or about October 23, 2009, over the First ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant Jong-Kwan Hong. During this interceptedconversation, defendant Sang-Hyun Park stated, “They say yours[sic] will be finally finished by November 15.” [a reference tothe build up following credit associated with the Chinese aliashe obtained from defendant Sang-Hyun Park]. Later during theconversation, defendant Jong-Kwan Hong asked, “And, have youstarted that about which President Na [a co-conspirator] talked,when I went to have a haircut.” Defendant Sang-Hyun Parkreplied, “Now, I’ve begun the build up” Defendant Sang-Hyun Parkstated that he just received a Nevada identification for [a co-conspirator].

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e. On or about November 11, 2009, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Jong-Kwan Hong. During this interceptedconversation, defendant Jong-Kwan Hong stated that he receivedpapers from two credit reporting agencies. Defendant Sang-HyunPark explained that the papers related to the addressverification [necessary for the credit build up to establish theveracity of the individual’s credit history]. Defendant Sang-Hyun Park instructed defendant Jong-Kwan Hong to bring thedocuments to defendant Sang-Hyun Park. Later during theconversation, they agreed that defendant Jong-Kwan Hong would goto defendant Sang-Hyun Park’s office on or about November 16,2009.

f. On or about November 16, 2009, a law enforcementofficer conducting surveillance near defendant Sang-Hyun Park’sBergen Turnpike Office observed and video recorded a silverLexus, registered to female with the last same last name andaddress as defendant Jong-Kwan Hong, entering and exiting aparking adjacent to the Bergen Turnpike Office.

g. Beginning in or about December 2009, defendantJong-Kwan Hong, using the Chinese name Dongshu Li and acorresponding 586 social security number, applied for andobtained six credit cards in the name of Dongshu Li. Numerouscharges were made on each credit card but were not paid,resulting in a total loss of approximately $9,600.

h. On or about December 21, 2009, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Jong-Kwan Hong. During this interceptedconversation, defendant Sang-Hyun Park instructed defendant Jong-Kwan Hong to go to defendant Sang-Hyun Park’s office to beginapplying for credit cards.

i. Later that day, according to records fromTarget National Bank, an application for a credit card was madein the name of Dongshu Li with a corresponding 586 socialsecurity number, a counterfeit Nevada driver’s license, and areported address in Westbury, New York belonging to defendantJong-Kwan Hong. In addition, the phone number supplied on theapplication is the same telephone number that defendant Jong-KwanHong used to communicate with defendant Sang-Hyun Park over theFirst Park Facility. According to the Nevada Department of MotorVehicles, the Nevada driver’s license number listed on theapplication does not exist.

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j. According to records from Macy’s/BloomingdaleFraud Department, on or about April 7, 2010, a charge of $60 wasattempted but declined on a credit card issued in the name ofDongshu Li with a corresponding 586 social security number.

l. On or about April 8, 2010, over the First ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant Jong-Kwan Hong. During this interceptedconversation, defendant Jong-Kwan Hong complained that heattempted to use a Bloomingdale’s credit card to make a $60purchase, but the transaction was denied.

81. Defendant In-Sook Lee

a. As described in Paragraph 51 above, defendant InSook Lee, using the Chinese name Ping Fang and a corresponding586 social security number, fraudulently obtained anidentification card in that name from the IDMV.

b. On or about February 23, 2009, while at the BroadOffice, during a consensually recorded meeting (audio and video)with Cooperating Witness One, defendant Sang-Hyun Park was on thephone with a person referred to as “Young Woo.” Based on recordsfrom a telephone company, this phone number is used by defendantYoung-Woo Ji. During the conversation, in which only defendantSang-Hyun Park’s portion of the call is recorded (by CooperatingWitness One), defendant Park asked, “If [defendant Young-Woo Ji]had received a call from In-Sook [defendant In-Sook Lee] . . . .I told [her] to send all of them to you. When you receive them .. . . So I am telling you to help that kid [defendant In-SookLee] for that . . . . If the man calls you, make an effort tohelp with that kid’s thing?”

c. According to records from the United States PostalService, on or about September 15, 2009, an individual, using thename Ping Fang, a corresponding 586 social security number, and agenuinely issued Illinois driver’s license in that name,established a post office box at a mail drop facility inPalisades Park, New Jersey. The telephone number listed on theapplication for the mail drop is the same telephone numberdefendant In-Sook Lee used to communicate with defendant Sang-Hyun Park over the First Park Facility, as described below.

d. On or about October 20, 2009, over the First ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant In-Sook Lee. During this interceptedconversation, defendant Sang-Hyun Park stated that he had spokenwith defendant Young-Woo Ji, and they discussed moving her

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address from a post office box to another address in anticipationof the completion of her credit build up. Defendant Sang-HyunPark further stated, “And, also there was one I made before [foryou], right? . . . . Have to do that quickly too, open the bankaccount.”

e. On or about January 6, 2010, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant In-Sook Lee. During this interceptedconversation, defendant In-Sook Lee asked defendant Sang-HyunPark for the name of the owner of Li Nails. Defendant Sang-HyunPark replied Zhen Li, a male. [As described in Paragraph 51above, defendant Sang-Hyun Park obtained a Illinoisidentification card using the Chinese name of Zhen Li and acorresponding 586 social security number. Defendant Sang-HyunPark incorporated or caused to be incorporated Li Nails using thefraudulently obtained identity Zhen Li].

f. On or about January 6, 2010, over the Second ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Young-Woo Ji. During this intercepted phonecall, defendant Young-Woo Ji stated, “Please have Hyun-Jin LNU[defendant Hyun-Jin LNU] make a deposit of $500 into my account[later that day, during a subsequent conversation, defendantYoung-Woo Ji identified this account as ZZ Entertainment].” Later during the conversation, defendant Sang-Hyun Park asked,“How is In Sook’s thing going [defendant In-Sook Lee]?” Defendant Young-Woo Ji replied, “In Sook’s?. . . . I have not runIn Sook’s, but her’s [sic] will be done well. . . . It will bedone . . . soon. . . . So please don’t give me stress with InSook’s.”

g. On or about April 24, 2010, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant In-Sook Lee. During this interceptedconversation, defendant In-Sook Lee stated, “Big Sister Hyun-JinLNU is not answering the phone . . . I have to work on Monday ofnext week. Can I come over next Tuesday [April 27, 2010].” Defendant Sang-Hyun Park replied, “I will talk to them.”

h. According to records from GE Money Bank/Wal-Mart,on or about or about April 27, 2010, an individual using theChinese name Ping Fang, the fraudulently obtained Illinoisidentification, and a corresponding 586 social security number,applied for and received a credit card from GE Money Bank/Wal-Mart. On or about May 11, 2010, this credit card was charged byCocoxu in the amount of approximately $710.62. This charge,

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together with other charges, was not paid, resulting in a totalloss of approximately $1,000.

i. On or about May 25, 2010, according to recordsfrom TD Bank and photographs from the bank’s surveillance video,defendant In-Sook Lee entered a bank branch in Bergen County, NewJersey and opened a checking account in the name of Ping Fang, aChinese name, using an Illinois driver’s license in that name,and a corresponding 586 social security number (which socialsecurity number was not issued to defendant In-Sook Lee by theUnited States). Furthermore, photographs from the bank’ssurveillance video reveals that defendant Osung Kwon accompanieddefendant In-Sook Lee into the bank. After opening this account,defendant In-Sook Lee applied for and received a TD Bank creditcard in the name of Ping Fang with a corresponding 586 socialsecurity number.

82. Defendant Sung-Rok Joh

a. As described in Paragraph 51 above, defendantSung-Rok Joh, using the Chinese name Zhang Li and a corresponding586 social security number, fraudulently obtained anidentification card in that name from the IDMV.

b. Beginning in or about April 2009, according torecords from Macy’s, GE Money Bank/Brooks Brothers, GE MoneyBank/PC Richard, Sears, Home Depot, and HSBC/Saks Fifth Avenue,an individual using the Chinese name Zhang Li, a corresponding586 social security number, and a fraudulently obtained Illinoisidentification card that he had obtained, applied for andreceived several credit cards in the name of Zhang Li. Based onthis investigation, Your Affiant believes that defendant Sung-RokJoh is the individual who obtained this credit card using theChinese name Zhang Li with the corresponding 586 social securitynumber. Numerous charges were made on these credit cards thatwere not paid, resulting in a loss of approximately $24,000.

83. Defendant Jung-Bong Lee

a. As described in Paragraph 51 above, defendant JungBong Lee, using the Chinese name Hong Guo Cui and a corresponding586 social security number, fraudulently obtained anidentification card and a driver’s license in that name from theIDMV. Defendant Jung Bong Lee, using the Chinese name Wei XiangLu and a corresponding 586 social security number, fraudulentlyobtained a driver’s license in that name from the PennDOT.

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b. On or about September 17, 2009, over the FirstPark Facility, defendant Sang-Hyun Park made an outgoingtelephone call to defendant Jung-Bong Lee. During thisintercepted conversation, defendant Jung-Bong Lee stated, “Therewas no call about the build up.” Defendant Sang-Hyun Parkresponded, “It seems that the build up isn’t done yet.” Defendant Sang-Hyun Park asked if defendant Jung-Bong Lee hadopened bank accounts, and defendant Jung-Bong Lee replied that heopened a Bank of America account. Later during thisconversation, defendant Jung-Bong Lee stated, “That’s why I’m now. . . the reason for applying for a BOA security card is thatthere’s the matter with doing the second round . . . .” Defendant Jung-Bong Lee stated that he would be satisfied if hecould obtain approximately $30,000 from the bank.

c. According to records from various credit cardcompanies and a credit reporting agency, in or about July 2009,defendant Jung-Bong Lee, using the Chinese name Wei Xiang Lu, acorresponding 586 social security number, the fraudulentlyobtained Pennsylvania driver’s license (with photograph) that heobtained, a Citibank credit card in the name of Wei Xiang Lu, andan addressed used by him, applied for and obtained a Capital Onecredit card. In addition, during this period, defendant Jung-Bong Lee, using the same fraudulently obtained Chinese identity,applied for and obtained approximately eleven other credit cardsfrom Citibank, Bloomingdale’s, Macy’s, HSBC Bank, HSBCBank/Nieman Marcus, and PNC Bank, among others. The followingtable sets forth some of the fraudulent charges made on creditcards obtained in the name of Wei Xiang Lu, among others:


Amount Description

May 21,2009

Citibank $940 Charge through a co-conspirator-financialconsulting service (i.e.,“kkang”)

August 7,2009

HSBCBank/NiemanMarcus

$990 Gucci handbag

August 7,2009

HSBCBank/NiemanMarcus

$420 Cristalle Eau VertePerform

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d. These charges and other were made on these creditcards obtained in the name of Wei Xiang Lu. These charges werenot paid, resulting in loss of approximately $44,000.

e. According to records from various credit cardcompanies and a credit reporting agency, beginning in or about February 2009, defendant Jung-Bong Lee, using the Chinese nameHong Guo Cui, a corresponding 586 social security number, and the fraudulently obtained Illinois driver’s license that he hadobtained, applied for and obtained credit cards from Chase Bank,Macy’s, and HSBC Bank/Saks Fifth Avenue and other credit cardcompanies. Based on this investigation, Your Affiant believesthat defendant Jung-Bong Lee is the individual who obtained thesecredit cards using the Chinese name Hong Guo Cui with acorresponding 586 social security number.

f. The following table sets forth some of thefraudulent charges made on credit cards obtained in the name ofHong Guo Cui, among others:


Amount Description

April 22,2009

Chase Bank $1,250 Wooden Furs

May 18,2009

HSBC Bank/SaksFifth Avenue

$4,000 Polo Ralph Lauren

May 26,2009


$11,122 Cartier Watch

May 27,2009


$716 Louis Vuitton leathergoods

May 27,2009


$835 Gucci fashion shoes

g. These charges and other were made on these creditcards obtained in the name of Hong Guo Cui. These charges werenot paid, resulting in loss of approximately $55,000.

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84. Defendant Hye-Won Jung

a. On or about September 8, 2009, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Hye-Won Jung. During this interceptedconversation, defendant Hye-Won Jung asked about a passport thatarrived. Defendant Sang-Hyun Park responded, “Your passport? [I/we] need to get it ready. Build up isn’t complete yet. First, need to open bank account and then do it. . . . Let me dothe work here [first] and [we] can do it one at a time, okay?” Defendant Hye-Won Jung then asked, “[W]e’re not doing the car?” Defendant Sang-Hyun Park replied, “What about the car? Need tobuy a car but [you] can’t buy it in your name because your creditfell to 500. . . . You can’t do anything with your credit.” Theyagreed to meet later that night.

b. On or about September 15, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from defendant Hye-Won Jung. During thisintercepted conversation, defendant Sang-Hyun Park asked, “Didyou hear from Hyun-Jin LNU [defendant Hyun-Jin LNU]? The card ismissing. . . . I instructed Hyun-Jin LNU to put up the Chinesename on the mailbox on her way home.” Defendant Hye-Won Jungreplied, “Well, all the mail did come.” Later during theconversation, defendant Sang-Hyun Park instructed defendant Hye-Won Jung to “go to the bank tomorrow . . . . You need to re-applyfor the debit card tomorrow. Wait, Hyun-Jin LNU already appliedso you only have to pick [it] up. Also, one more. Bring all themoney, stock and cash.”

c. On or about September 24, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from defendant Hye-Won Jung using a phone numberfrom Li Nail, d/b/a “Nails Plus,” in Hopatcong, New Jersey. During this intercepted conversation, defendant Sang-Hyun Parkasked if a call from Citibank was received at the store lookingfor Mingyu Jin [A Chinese name with a corresponding 586 socialsecurity number]. According to a credit reporting agency, MingyuJin was reportedly employed by Nail Plus. Moreover, numerouscredit cards were obtained in this name and corresponding socialsecurity number. In total, approximately $16,000 in loss isassociated with these credit cards]. Defendant Hye-Won Jungreplied that no such call was received. Defendant Sang-Hyun Parkstated, “[W]hen [the call] comes say [Mingyu Jin is] outregardless and give me a call and get the number. You know whatI am saying?. . . . You know the name [Mingyu Jin], if they ask[if that person] works, tell them correct [i.e., yes] that personworks [at the store] and . . . ask them to leave a message. . . .

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[d]on’t make a mistake.” Defendant Hye-Won Jung replied, “I gotit.” Defendant Sang-Hyun Park again reminded defendant Hye-WonJung “[s]o [if] a call for [Mingyu Jin] comes, answer it well. .. . Got it?” Defendant Hye-Won Jung replied, “It’s a third time[sic] telling me the same thing.” Defendant Sang-Hyun Parkcontinued: “So, tell [the] employee[s] [at the salon], you don’thave to say who [Mingyu Jin] is but if they look for that person,educate the [employees] to say [Mingyu Jin is] not there. . . .” Later during the conversation, the following discussion ensued:

Park: Yeah, your passport you, did with?Jung: Is that all prepared?Park: No, a build up is still being done but open

an account in advance and have to use themoney coming and going. . . .

d. On or about June 2, 2010, according to recordsfrom Valley National Bank and photographs from the bank’ssurveillance video, defendant Hye-Won Jung entered a bank branchin Bergen County, New Jersey and opened an account in the name of Meihong He, a Chinese name, using a counterfeit Californiadriver’s license and a corresponding 586 social security number(which social security number was not issued to defendant Hye-WonJung by the United States). Furthermore, photographs from thebank’s surveillance video reveals that defendant Osung Kwonaccompanied defendant Hye-Won Jung into the bank. On theapplication to open the account, defendant Hye-Won Jung, usingthe name Meihong He, listed her employment as Moja Trading, acompany controlled by defendant Sang-Hyun Park.

e. On or about June 23, 2010, according to recordsfrom Valley National Bank and photographs from the bank’ssurveillance video, defendant Joong-Hyun Jung entered a ValleyNational Bank in Bergen County, New Jersey and deposited a checkin the amount of $3,500, drawn on the account of “Cheng Yu Ma” [aChinese identity with a corresponding 586 social securitynumber], into the account in the name of Meihong He [the Chineseidentity used by defendant Hye-Won Jung]. This check wasreturned for insufficient funds.

f. From in or about March 2010 through in or aboutJuly 2010, defendant Hye-Won Jung, using the identity Meihong Heand a corresponding 586 social security number, obtainedapproximately ten credit cards and lines of credit from variouscredit card companies and retail stores. These charges were notpaid, resulting in a total loss of approximately $8,000.

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85. Defendants Son-Hee Chong and In-Suk Joo

a. On or about September 14, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from defendant In-Suk Joo. During thisintercepted conversation, defendant In-Suk Joo stated that shehad previously gone to his office and asked about “the Chinesecredit.” Defendant In-Suk Joo further asked, “I told my friendthat I needed money. How much is it?” Defendant Sang-Hyun Parkreplied, “Which one exactly? Did you call about the driver’slicense?” Defendant In-Suk Joo stated that she wanted thedriver’s license and “the Chinese credit.” Defendant Sang-HyunPark advised defendant In-Suk Joo that “[t]otally, it costs$7,000.”

b. On or about September 15, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from defendant In-Suk Joo. During thisintercepted conversation, defendant In-Suk Joo stated, “I cameover yesterday, do you remember? Three ladies?. . . . Can wemeet at 8:00 this evening.” Defendant Sang-Hyun Park agreed tomeet her and asked if everything was prepared. Defendant In-SukJoo stated, “Yes, I will do it.”

c. After the call referred to in Paragraph 29b above,on or about September 15, 2009, over the First Park Facility,defendant Sang-Hyun Park received an incoming telephone call fromdefendant Son-Hee Chong. During this intercepted conversation,defendant Son-Hee Chong stated, “You met two others earlier andyou met me yesterday for the first time, right?” Defendant Sang-Hyun Park acknowledged meeting her. Defendant Son-Hee Chong thenconfirmed that she and the two others would meet defendant Sang-Hyun Park later that night.

d. On or about September 15, 2009, a law enforcementofficer was conducting surveillance near the Broad Office. During this surveillance, the law enforcement officer observedthree older Korean females exit defendant Sang-Hyun Park’sbuilding and enter a black Lexus.

e. On or about September 15, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from defendant Dong-Won Kim. During thisintercepted conversation, defendant Sang-Hyun Park asked ifdefendant Dong-Won Kim found “out about the social.” DefendantDong-Won Kim replied that he was waiting for a phone call. Defendant Sang-Hyun Park then stated that he needed four socialsecurity cards. Defendant Dong-Won Kim asked, “[w]hat birth

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year?,” and defendant Sang-Hyun Park stated that it should be fora female of about 50 years of age. Sang-Hyun Park askeddefendant Dong-Won Kim to rush the request.

f. On or about September 16, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from defendant Dong-Won Kim. During thisintercepted conversation, defendant Dong-Won Kim stated that hehad no social security cards for birth years in the 1960s. Defendant Sang-Hyun Park stated, “These people are too old topass as the 7s [individuals born in the 1970s]. . . . [T]hese aremiddle aged woman, almost in their late 50s. . . . It’s a nailshop lady through an introduction from someone. . . . I got allthe money yesterday.” Defendant Son-Hee Chong was observed by alaw enforcement officer operating a nail saloon.

g. On or about September 17, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from defendant In-Suk Joo. During thisintercepted conversation, defendant In-Suk Joo identified herselfas “Mrs. Joo who went there before.” Defendant Sang-Hyun Parkasked, “Why are you not bringing the picture, picture, picture?” Defendant In-Suk Joo said that she had to take the picture. Defendant Sang-Hyun Park stressed that she needed to bring himthe picture immediately so that he “could work on the ID.” Defendant In-Suk Joo asked if he was able to obtain a socialsecurity number corresponding to her age. Defendant Sang-HyunPark replied, “I can’t give the exact one . . . . the only way isto make it younger, born in the 60s.” [see Paragraphs 85n, 85o,and 85p below relating to a 586 social security number used bydefendant In-Suk Joo].

h. On or about September 23, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from defendant In-Suk Joo. During thisintercepted conversation, defendant In-Suk Joo stated, “Our IDcase . . . did it get filed? Don’t you need the address?” Defendant Sang-Hyun Park replied, “The address is not included .. . . The ID is from another state. Another state. . . . When itcomes, there is a lot to prepare.”

i. On or about September 30, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from defendant In-Suk Joo. During thisintercepted conversation, they discussed a remaining payment ofapproximately $9,000.

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j. On or about September 30, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from defendant Son-Hee Chong. During thisintercepted conversation, defendant Son-Hee Chong confirmedgiving a photograph to defendant Sang-Hyun Park. Defendant Sang-Hyun Park stated, “The ID should come this weekend. . . . Whenwill you pay the balance.” “I already gave you for the two. . .. Gave you $14,000,” defendant Son-Hee Chong replied. DefendantSang-Hyun Park stated, “You gave me some out of $21,000 thattime. And you said you didn’t have the rest and ask for myunderstanding. . . .” She replied, “I gave you $12,000 thattime,” and defendant Sang-Hyun Park replied, “Yes, you gave me$12,000.” Later during the conversation, defendant Sang-HyunPark stated, “I requested [the] ID on [September 22, 2009] forChong Son-Hee [defendant Son-Hee Chong].” Defendant Sang-HyunPark advised her that it would take approximately two to threemonths to complete the build up, and he would “make Nevadadriver’s license.”

k. On or about October 16, 2009, over the First ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant Dong-Won Kim. During the conversation, Sang-Hyun Park ordered three social security cards from defendantDong-Won Kim. Defendant Sang-Hyun Park stated, “Yes, three hasbeen [sic] confirmed. [Born 19]70s, males . . . . Doesn’t matterif [born in] 75, 76, 72. . . .”

l. On or about October 19, 2009, over the First ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant In-Suk Joo. During this interceptedconversation, defendant Sang-Hyun Park stated, “ I called youbecause . . . . I was trying to do build up but the address . . .I realized I hadn’t received your address. . . . You can use yourhome address. I doesn’t matter.” Thereafter, defendant In-SukJoo provided her actual home address in Clark, New Jersey todefendant Sang-Hyun Park over the phone. The address sheprovided to defendant Sang-Hyun Park corresponding the address onher genuinely issued New Jersey driver’s license.

m. On or about November 9, 2009, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant In-Suk Joo. During this interceptedconversation, defendant In-Suk Joo asked for a status, anddefendant Sang-Hyun Park replied, “Build up is in process so youneed to wait . . . . Which person were you among the three?” Shereplied, “In-Suk Joo, Joo! . . . . Chong [defendant Son-HeeChong] [came before me].” Defendant Sang-Hyun Park advised herto be prepared to open bank accounts in the following weeks.

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n. In or about April 2010, according to records fromChase Bank, Citibank, and a credit reporting agency, anindividual using the Chinese name Danhua Wang, a corresponding586 social security card (related to a 1961 birth year), acounterfeit Nevada driver’s license, and defendant In-Suk Joo’saddress in Clark, New Jersey, applied for and received creditcards from Chase Bank, Citibank, Bloomingdale’s, and GE MoneyBank/Walmart. Based on this investigation, Your Affiant believesthat defendant In-Suk Joo is the individual who obtained thesecredit cards using the Chinese name Danhua Wang with thecorresponding 586 social security number.

o. The following table sets forth some of thefraudulent charges made on credit cards obtained in the name ofDanhua Wang (“kkang”):


Amount Description

May 4,2010

Chase $520 Charge through Li NailsPlus

May 6,2010

Chase $3,659 Charge through Cocoxu

p. Numerous charges were made on credit cards issuedin the name of Danhua Wang that were not paid, resulting in aloss of approximately $10,000.

q. On or about June 28, 2010, according to recordsfrom Valley National Bank and photographs from the bank’ssurveillance video, defendant Son-Hee Chong entered a ValleyNational Bank in Bergen County and opened an account in the nameof Mingshun Yuan, a Chinese name, a corresponding 586 socialsecurity number (which social security number was not issued todefendant Son-Hee Chong by the United States), a counterfeitNevada driver’s license, (a copy of which was retained by thebank and bears a photograph of defendant Son-Hee Chong), and acorresponding 586 social security number. Furthermore,photographs from the bank’s surveillance video reveals thatdefendant Osung Kwon accompanied defendant Son-Hee Chong into thebank. On the application to open the account, defendant Son-HeeChong, using the name Mingshun Yuan, listed her actual homeaddress in Palisades Park, New Jersey (where a law enforcementofficer, while conducting surveillance, observed defendant Son-Hee Chong enter and exit). The bank, however, immediately closedthe account.

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86. Defendant Byung Jang

a. On or about September 21, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from defendant Byung Jang. During thisintercepted conversation, the following discussion ensued:

Park: Hello?Jang: Hello?Park: Yes, big brother, it’s me.Jang: Yes, you called.Park: Didn’t [you] have a 586 [social security

card] in the past?Jang: 586? I did.Park: But that is now, is it still alive in the

bank?Jang: That, I don’t know if it’s still alive in the

bank or not. There’s no ID, no ID.Park: No ID?Jang: Yes. No ID for 586.Park: So, you did it without ID or any?Jang: There wasn’t any, at the time, [I] made a

passport and gave it to [a co-conspirator]and finished. . . . [Co-conspirator] and Iwent there to make a license. . . . I had itand then [I] [threw it away].

Park: What was it that [you] made licenses at thattime?

Jang: At that time, when we went, [I] passed the[driver] license but when [I] had to go for adriving test, [I] didn’t go but instead[I] just got $30,000 or something at the bankand quit. Extracted a credit card. And then[I] withdrew without doing anything. It’sprobably still alive in Wachovia and such butthe problem is the passport, because there’sno passport, there’s no ID.

Park: You didn’t have a copy of ID, anything atthat time?

Jang: Right, I gave them all without making copies.Park: And, you made a license or something with me

last time, lousy one [counterfeit].Jang: That, that was a TD Bank.Park: What was it?Jang: TD Bank, no that, that’s my original, that

is. That’s of course a [fake?], we made itto bust out on a Citibank. . . . . There’s noID for that, either.

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Park: There’s no ID, you said?Jang: Yes, how can a lousy one go around? That I

made it through [Co-conspirator] for $800, .. . did it but didn’t work out at the end

Park: Ah, so?Jang: Yeah. So, leave it or use it with a bill

later, you have to think about it later.After some time passes. There’s a loan I gotfrom Citibank but it failed while trying todo.

Park: So, the problem is that there are no IDs atall, right?

* * * *

Park: 586. . . . Jang: Yes, same with 586 and other things are the

same and I didn’t request lots of checks,that sort of things do exist.

* * * *

Park: Did you have that lousy ID [counterfeit] thatyou made?

Jang: Which one?Park: The lousy one you made at that time?Jang: The lousy one, I cut it off.Park: You cut it off.Jang: Yeah, if I keep it, that’s anyway, it’s too

lousy and why would I keep it when it’s tooinadequate. It’s completely inadequate.

* * * *

Park: What was it about, that passport was madefor?

Jang: Citibank, Citibank.Park: The name, the name. What was the name?Jang: An that’s P, Byung Jang but it’s P, Pyung

Jang.Park: Ah, the one with a Korean name?Jang: Yeah, it’s Pyung Jang. It starts with 137

because it’s mine. Ah, that came from LosAngeles, too.

Park: What came from LA?Jang: That TD Bank thing.Park: There was only TD Bank one with that name,

and not any other account?

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Jang: Right, I didn’t even make other accounts. Ihad a few cards, Capitol, Bank of America anda few.

b. Beginning in or about November 2008, defendantByung Jang, using the Chinese name Xue Hui Shi and acorresponding 586 social security number, applied for andreceived credit cards issued by Bank of America, Chase Bank, HSBCSaks Fifth Avenue, PNC Bank, and Citibank. According to recordsBank of America, HSBC Saks Fifth Avenue, and PNC Bank, defendantByung Jang applied for these credit cards and listed his actualFort Lee, New Jersey address. Furthermore, according to recordsfrom Toyota Motor Credit Corporation, on or about September 8,2009, defendant Byung Jang applied for and received a car loan inBergen County, New Jersey, in the approximate amount of $22,500,from Toyota Motor Credit Corporation to purchase a black, 2010Toyota Camry. On the application, defendant Byung Jangrepresented he was the owner of Yuri Beauty Salon, Closter, NewJersey with a reported income of $5,000 per month.

c. According to records from PNC Bank, a PNC BankVisa credit card, in the name of Xue Hui Shi, was charged through“Yuri Hair Salon.” These charges, among others, were not paid,resulting in a loss of approximately $9,400.

87. Defendant Amy Yang (see Paragraphs 51 and 72 above).

88. Defendants Song-Ja Park and Min-Jun Kwon

a. On or about January 23, 2010, over the Second ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant Min-Jun Kwon. During the interceptedconversation, th following discussion ensued, in substance and inpart:

Kwon: Yes, president.Park: I heard everything went well.Kwon: Yes. I just picked up the mails.Park: Yes.Kwon: The Target card [with] the same address.Park: It came?Kwon: Yes. The address and.Park: It came with the card, right?Kwon: Yes, yes. It came with the card.Park: . . . . Then please bring us the Macy [card]

and the temporary card, so we could find outhow much it/they worth over the phone onMonday.

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Kwon: Brother Dong-il [defendant Dong-Il Kim] hasit.

Park: Huh?Kwon: Brother Dong-il has it.Park: Dong-il? He said he doesn’t have it.Kwon: Huh?Park: Ask your mother [defendant Song-Ja Park].

The temporary card, one that got approved.Kwon: Which card? [My mother] told me she gave it

to brother Dong-il [defendant Dong-Il Kim].Park: Macy’s. . . . . Dong-il says he never got it.

. . . Okay, see if you have it. Ask yourmother [Song-Ja Park].

b. On or about January 23, 2010, over the Second ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant Min-Jun Kwon. During the interceptedconversation, the following discussion ensued, in substance andin part:

Park: Yes, Kwon.Kwon: Yes, but we don’t have it here.Park: What do mean? Just a moment, I will let you

talk to Dong-il [defendant Dong-Il Kim].Kwon: Yes.Park: [To defendant Dong-Il Kim]. He said he

doesn’t have it.Kim: Hello?Kwon: Yes, big brother.Kim: Ask [defendant Song-Ja Park] to look inside

the shopping bag, again I, the mailing. . . .Kwon: Yes, yes.Kim: I just brought [the mail] with me. . . . Two

IDs and address for verification...

c. In or about January 2010, Target National Bankissued a credit card in the name of Run Hong Liu.

d. In or about January 2010, Macy’s issued a creditcard in the name of Run Hong Liu, resulting in a loss ofapproximately $3,000.

e. In or about January 2010, Bloomingdale’s issued acredit card in the name of Run Hong Liu, resulting in a loss ofapproximately $3,000.

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f. On or about February 4, 2010, according to recordsfrom Chase Manhattan Bank and photographs from the bank’ssurveillance video and law enforcement surveillance, defendantSong-Ja Park entered a bank branch in Bergen County, New Jerseyand opened a checking account in the name of Run Hong Liu, aChinese name, using a counterfeit California driver’s license,and a corresponding 586 social security number (which socialsecurity number was not issued to defendant Song-Ja Park by theUnited States). In addition to opening this account, defendantSong-Ja Park also obtained a debit card in the name of Run HongLiu from this bank. Photographs from the bank’s surveillancevideo reveals that defendant Dong-Il Kim accompanied defendantSong-Ja Park into the bank.

g. On or about February 4, 2010, federal agents wereconducting surveillance near defendant Sang-Hyun Park’s BergenTurnpike Office. These federal agents observed a car registeredto defendant Min-Jun Kwon depart the Bergen Turnpike Office. Thefederal agents followed this car to the Chase Manhattan Bank. Thereafter, this surveillance team took a series of photographsshowing defendants Dong-Il Kim and Song-Ja Park departing thebank and entering defendant Min-Jun Kwon’s car.

h. In or about March 2010, Citibank issued a creditcard in the name of Run Hong Liu, resulting in a loss ofapproximately $2,000.

i. On or about April 2, 2010, a charge, in theapproximate amount of $20, was made on a debit card issued to theRun Hong Liu at Cello Hair, a company owned and operated bydefendant Sung-Sil Joh.

j. In or about April 2010, Chase Bank issued a creditcard in the name of Run Hong Liu. On or about April 20, 2010, acharge, in the approximate amount of $3,735, was made on this credit card at a liquor store in Bergen County, New Jersey. Thecharges on this card were not paid, resulting in a loss ofapproximately $4,000.

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89. Defendant Hag-Sang Jang

a. On or about January 13, 2010, over the First ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant Jong-Hoon Kim. During this interceptedconversation, defendant Sang-Hyun Park stated that he received acall from a prospective customer who wanted to bust out hiscredit cards. Defendant Sang-Hyun Park provided the prospectivecustomer’s last name, telephone number, and location of residenceto defendant Jong-Hoon Kim and asked him to “give [theprospective customer] a consultation?” Defendant Sang-Hyun Parkstated that the customer had at least six credit cards and “itseems like his remaining limit is more than enough[,] [and] [h]ewants me to get the readjustment, and he wants me to take out thecash from them. . . . If he wants to get the readjustment, thatmeans, he said he can’t make payments at all. . . . So he calledme to take the cash out.” Based on this information, togetherwith other information, Your Affiant believes that defendantSang-Hyun Park was referring to defendant Hag-Sang Jang.

b. On or about January 14, 2010, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Jong-Hoon Kim. During this interceptedconversation, defendant Sang-Hyun Park asked if he had spokenwith the “old man” [defendant Hag-Sang Jang]. Defendant Jong-Hoon Kim replied, “I just did. Gosh. I had to talk to him fortwo hours.” Defendant Jong-Hoon Kim added, “There is a goodamount” [of credit remaining on the credit cards]. DefendantJong-Hoon Kim also advised defendant Sang-Hyun Park thatdefendant Hag-Sang Jang sought a consultation from another localbroker in the area.

c. On or about January 16, 2010, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Jong-Hoon Kim. During this interceptedconversation, defendant Jong-Hoon Kim stated, “The gentlemen[defendant Hag-Sang Jang] came by my office here. It looks likeavailable cash for the first round amounts anywhere from $20,000to $23,000. . . . If you are okay with me bringing him here, wecan go do the first round now. And the remaining job can be donein my office. . . . Defendant Sang-Hyun Park replied, “Okay.”

d. On or about January 16, 2010, a law enforcementofficer was conducting surveillance near defendant Jong-HoonKim’s office in Ridgefield, New Jersey. During thissurveillance, the law enforcement officer observed and videorecorded a car, registered to defendant Hag-Sang Jang, in aparking lot adjacent to Jong-Hoon Kim’s office building.

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Thereafter, a car, registered to a company affiliated withdefendant Jong-Hoon Kim, was observed leaving the building, anddefendants Jong-Hoon Kim and Hag-Sang Jang were observed in thiscar. The law enforcement officer followed this car, containingthe two aforementioned defendants, to the Bergen Turnpike Office.

e. On or about January 16, 2010, at approximately11:12 a.m., over the First Park Facility, defendant Sang-HyunPark received an incoming telephone call from defendant Jong-HoonKim. During this intercepted conversation, defendant Jong-HoonKim stated, “Open the door, please.”

f. On or about January 16, 2010, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Jong-Hoon Kim. During this interceptedconversation, defendant Sang-Hyun Park asked, “So how much worthdid you buy?” Defendant Jong-Hoon Kim replied that he purchased$2,500 worth of an unidentified product.

g. On or about January 16, 2010, the following creditcard charges were made on credit cards issued to defendant Hag-Sang Jang or his business, H and S Construction:

Credit Card Merchant ApproximateAmount

Visa (company) Red Coco Int’l $3,000

Visa (company) New M and K Global $3,210

Visa (company) 153 Samsung DC $1,500

Bank of America(personal)

Li Nails Plus $3,389

US Bank#1 (personal) Liaison Inc. [a company allegedlyheadquartered in NewYork]

$3,450

US Bank#2 (personal) The Shop atRiverside,Hackensack, NewJersey

$3,017

US Bank#2 (personal) Saks Fifth Avenue,Hackensack, NewJersey

$1,100

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h. On or about January 28, 2010, according to recordsfrom Bank of America and photographs from the bank’s surveillancevideo, defendant Hyun-Jin LNU entered a bank branch in BergenCounty, New Jersey and made a payment in the form of a check tothe Bank of America credit card (personal) belonging to defendantHag S. Jang in the amount of $8,700. This check was drawn on theCitibank account of Cheng Yu Ma [a Chinese name with acorresponding 586 social security number]. This check wasreturned for insufficient funds.

i. According to PNC Bank, the charges on credit cardsissued to defendant were not paid, resulting in a loss ofapproximately $23,000.

j. According to U.S. Bank, the charges on creditcards issued to defendant were not paid, resulting in a loss ofapproximately $23,000.

90. Defendant Jung-Sook Ko

a. As described in Paragraph 51 above, defendant JungSook Ko, using the Chinese name Haishun Jin and a corresponding586 social security number, fraudulently obtained anidentification card and a driver’s license in that name from theIDMV.

b. On or about January 8, 2010, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Jung-Sook Ko. During this interceptedconversation, defendant Jung-Sook Ko asked, “Isn’t time to domine now?” Defendant Sang-Hyun Park replied, Yes, I should. Iam too busy these days.” Defendant Jung-Sook Ko replied, “Now ithas been more than one year. . . . Please bear that in mind. Andthere are lots of mail [sic] for Big Brother [defendant Myung-Kyun Ko, a/k/a “Longnan Cui,” is defendant Jung-Sook Ko’sbrother] so give me a call. I will [give the mail to you].”

c. Beginning in about February 2010, according torecords from Macy’s, Bloomingdale’s, Saks Fifth Avenue,Nordstrom, Citibank, Chase, Bank of America, and HSBC Bank,defendant Jung-Sook Ko, using the Chinese name Haishun Jin, acorresponding 586 social security number, and the fraudulentlyobtained Illinois driver’s license that she had obtained, appliedfor and received approximately eight credit cards. Numerouscharges were made on these credit cards that were not paid,resulting in a loss of approximately $18,000.

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d. On or about March 17, 2010, according to recordsfrom Valley National Bank and a photograph from the bank’ssurveillance video, defendants Hyun-Jin LNU and Jung-Sook Koentered a branch in Fort Lee, New Jersey, and opened an accountin the name of Haishun Jin with a corresponding 586 socialsecurity number.

91. Defendant Myung-Kyun Ko

a. As described in Paragraph 51 above, defendantMyung-Kyun Ko, using the Chinese name Longnan Cui and acorresponding 586 social security number, fraudulently obtainedan identification card in that name from the IDMV.

b. Beginning in or about September 2008, Myung-KyunKo, using the Chinese name Longnan Cui, a corresponding 586social security number, the fraudulently obtained Illinoisidentification card that he obtained, and an address belonging todefendant Myung-Kyun Ko, applied for and obtained credit cardsfrom Chase Bank, and Macy’s and other credit card companies.

c. The following table sets forth some of thefraudulent charges made on credit cards obtained in the name ofLongnan Cui, among others:


Amount Description

October16, 2008

Chase $2,780 Charge through AmethThread (a companycontrolled by defendantSang-Hyun Park)

May 14,2009

Bank ofAmerica

$4,780 Charge through ZI Int’l(a company controlled aco-conspirator)

May 16,2009

Chase $3,693 Saks Fifth Avenue formerchandise

May 16,2009

Chase $1,000 Abercrombie and Fitch

May 18,2009

Bank ofAmerica

$4,810 Charge through For YourJoy (a company controlledby FNU LNU#1, a/k/a “Mr.Choi” and “XijunGu”)

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d. The above charges and others were made on thesecredit cards but were not paid, resulting in a loss ofapproximately $90,000.

92. Defendant Yoon-Hee Park

a. As described in Paragraph 51 above, defendantYoon-Hee Park, using the Chinese name Zhangqi Zhang and acorresponding 586 social security number, fraudulently obtainedan identification card in that name from the IDMV. He alsofraudulently obtained an identification card in the name ofXiaofang Zhu from IDMV.

b. Beginning in or about June 2007, defendant Yoon-Hee Park, using the Chinese name Zhangqi Zhang, a corresponding586 social security number, and the fraudulently obtainedIllinois identification card that he had obtained, applied forand obtain a credit card from Best Buy. In addition, defendantYoon-Hee Park, using the same Chinese name and 586 socialsecurity number, applied for and obtained credit cards from Chase(three), Citibank (five lines of credit), and Macy’s. Numerouscharges were made on these credit cards that were not paid,resulting in a total loss of approximately $86,000.

c On or about February 24, 2010, New York,defendants Seung-Ho Noh and Yoon-Hee Park entered a Citibankbranch in Nassau County, New York. After they entered the bank,defendant Yoon-Hee Park, accompanied by defendant Seung-Ho Noh,attempted to open a business checking account in the name of“Yunny Enterprise” with an address corresponding to SunnyEnterprise, a store front located in Flushing, New York whichbusiness is used as a front to bust out credit cards. To openthis business account, defendant Yoon-Hee Park provided the bankwith a counterfeit New York State driver’s license and socialsecurity card. While defendant Yoon-Hee Park was completing theforms to open the account, the bank contacted law enforcement.

d Defendant Yoon-Hee Park, after being advised ofhis Miranda rights, told the police officers, in substance and inpart, he purchased a driver’s license from a “Chinese guy” forapproximately $500.

e After obtaining defendant Seung-Ho Noh’s consent,police officers his searched his car and seized to followingitems: (1) two checkbooks in the name of C.S.H. with an addressin Ridgefield, New Jersey; (2) a fraudulently obtained Illinoisdriver’s license in the name C.M.S., which name corresponds to a586 social security number; (3) a MasterCard credit card in the

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name of C.M.S.; (4) a genuinely issued New Jersey driver’slicense belonging to defendant Hag-Sang Jang; (5) an applicationform containing defendant Hag-Sang Jang’s personal information,including his address in Palisades Park, New Jersey, date ofbirth, and business information, specifically, KNC Trading, Inc.with an address in Oakland Gardens, New York, and a taxidentification number with the last four digits 4064; (6) agenuinely issued New York driver’s license in the name of B.H.L.with a corresponding genuinely issued social security card in thesame name; (7) an Illinois driver’s license in the name of Y.W.;and (8) a notebook containing numerous handwritten entriespertaining to names with corresponding 586 social securitynumbers, addresses, bank account numbers, email address andpasswords.

f. In addition to the items seized above, defendant Seung-Ho Noh, after being advised of his Miranda rights, made thefollowing statements, in substance and in part, to the policeofficers: (1) the notebook [see Paragraph 37e above] belonged tohim; and (2) he used checks from the checkbooks in the name ofC.S.H. to issue checks to himself, and he knew that the accountdid not belong to him.

g. On or about April 27, 2010, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Seung-Ho Noh. During this interceptedconversation, they discussed defendant Seung-Ho Noh’s arrest. The following ensued, in substance and in part:

Park: Yes.Noh: Hello?Park: Yes.Noh: Yes, eh. How are you? This is Mr. Noh. . .

. It’s Mr. Noh. Ha ha, you forgot, forgot mylast name. Ha ha ha ha.

* * * *

Park: At that time, I heard the rumor, somethingbad happened to you.

Noh: Ah. I just went together to open a bankaccount.

Park: What happened actually?Noh: Ah. Someone I knew. I wasn’t really close

with him but I wanted to open and do some[sic] check job. (emphasis added). So wewent to open some bank accounts.

Park: Yeah.

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Noh: It was no problem with Chase since I knew thebank.

Park: Yeah.Noh: Then we decided to go to Citi, but when we

were going to go to the Citibank, to theKorea, the area, the Korean, he hasdone some job in that area with 586 already[Your Affiant believes that defendant Seung-Ho Noh and defendant Yoon-Hee Park decidedagainst opening the account at a Citibankbecause defendant Yoon-Hee Park had alreadydefrauded that bank using a fraudulentlyobtained 586 identity].

Park: Ah.Noh: So we went to . . . [Nassau County]. Park: Yeah, yeah.Noh: But that man [defendant Yoon-Hee Park], I

knew he had an original licence. . . . [f]rom Pennsylvania.

Park: Yeah.Noh: But when he popped out a license, he pulled

out a New York one that looked like a obviousfake one. (emphasis added).

Park: The New York one?Noh: Yeah, yeah. The New York one that was made,

I mean.Park: Aha, the New York one that was made here, you

mean? (emphasis added).Noh: Yeah, yeah. He pulled out the fake one. Not

the Pennsylvania one but the fake one.Park: Umm.Noh: And then the bank teller was asking the

social number, why the social card lookedlike a blue print, [a] blue print [areference to being counterfeit].

Park: Yeah, yeah.Noh: He pulled that one out. At that moment, I

knew I was screwed. (emphasis added). Iasked him why he pulled that one out and whyhe even carried that. I asked him if he hada legitimate one. He said that he just usedit.

Park: Yeah.Noh: At that moment, the police caught up on us.Park: Umm.Noh: So we were all arrested.

* * * *

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Noh: You know that man [defendant Yoon-Hee Park]has made much money with the 586 goingthrough Citibank.

Park: Going through Citi?Noh: Yeah, yeah, going through Citibank.Park: Ah.Noh: So we went to the Citibank. But . . . that

area is . . . . well known for its verystrong police force in New York.

* * * *

Noh: So that, I, at that time, had some documentsin my car. What it was that I had somedocuments to do some tax work.

Park: Yeah.

* * * *

Noh: From my documents, they found his documentsabout taxes and the 586 social numbers. Allthose were in my briefcase. That was theproblem. I had a chance to get out but whenthey search my car, they found them in mybriefcase. So I was arrested together [sic]because they asked me what those [documents]were.

h. Law enforcement have reviewed defendant Seung-HoNoh’s notebook. The notebook contained approximately 60handwritten entries of Chinese names with corresponding 586social security numbers. In furtherance of the Park CriminalEnterprise, defendant Seung-Ho Noh and his co-conspirators usedthese fraudulently obtained 586 social security numbers to filefraudulent tax returns and obtain tax refunds from the InternalRevenue Service in 2008 and 2009, seeking approximately $500,000in refunds.

i. On or about December 30, 2009, over the First ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant Seung-Ho Noh. During this interceptedconversation, the following discussion ensued, in substance andin part:

Noh: Can I buy gift cards from Abercrombie [areference to Abercrombie and Fitch, retailclothing store]?

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Park: Yes, you can.Noh: Ah, then can I use it although the card was

issued not too long ago?

* * * *

Park: But, it’s hard for me to do if you make$1,000 or $2,000, you should do more than$5,000.

Noh: Man, I can only do up to $2,000.Park: Then, why are you trying to shop at

Abercrombie?

* * * *

Park: You can do kkang.Noh: Where?Park: Bring it over here, I will do it for you.Noh: Ah, then can it be done for 20%?Park: Yes, that’s better, if you are not doing the

big amount.Noh: Oh, I got it.Park: Bring in over. I will do it for you.

j. Later that day, during a subsequent telephone callover the First Target Facility, defendant Seung-Ho Noh asked,“[I]f I bring it tomorrow, can you get me some money? I amrather desperate for money.” Defendant Sang-Hyun Park replied,“Oooh. That won’t work. Money should come in before I give youthe cut.” Defendant Sang-Hyun Park stated that it would takeapproximately three days for the money to come in [from themerchant bank associated with defendant Sang-Hyun Park’s creditcard machines].

k. On or about December 31, 2009, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Seung-Ho Noh. During this interceptedconversation, defendant Seung-Ho Noh stated, “[I] swiped theDiscover card earlier . . . . I got the bill already. . . it was$80 something, can I bust it now or not yet?” Defendant Sang-Hyun Park replied, “Yes, you can. . . .”

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93. Defendant Alex S. Lee

a. On or about February 27, 2010, defendant Alex S.Lee entered a Saks Fifth Avenue store in Bergen County, NewJersey and opened a line of credit account with that store usinga counterfeit California driver’s license in the name of YicunZhu, a corresponding 586 social security number, and Macy’s Visacredit card in the name of Yicun Zhu. After opening this line ofcredit in the name of Yican Zhu, defendant Alex S. Lee purchasedapproximately $2,875.50 in merchandise from the store, includinga Louis Vuitton bag ($1,410), Louis Vuitton belt ($575), and aLouis Vuitton wallet ($740). After placing this merchandise inhis car, defendant Alex S. Lee returned to the store andattempted to open a second line of credit in the name of Yun Hu,using a Pennsylvania driver’s license (see Paragraph 51 above), acorresponding 586 social security number, and a Citibank creditcard in the name of Yun Hu. Thereafter, store personnelapproached defendant Alex S. Lee, he fled the store, and wasdetained. After local police arrested defendant Alex S. Lee, thefollowing items were found on his person: (a) documents relatedto two TD Bank accounts opened in the name of Yicun Zhu and YunHu; (b) documents related to a Citibank account opened in thename of Yicun Zhu; (c) documents related to a checking account atWachovia opened in the name of Yun Hu; (d) documents related to achecking account at Chase opened in the name of Yun Hu; (e) agenuinely issued but fraudulently obtained Pennsylvania driver’slicense in the name of Yun Hu; (f) a counterfeit California driver’s license in the name of Yicun Zhu; (g) a Macy’s creditcard in the name of Yicun Zhu; (h) a Citibank credit card in thename of Yun Hu; and (i) a receipt from PC Richard and Son,located in Bergen County, New Jersey, for the purchase of a$2,049.97 flat screen television purchased using the name YicunZhu (defendant Alex S. Lee used the Yican Zhu identity to obtaina charge account at PC Richard and Son, which charge account wasused to purchase the flat screen television).

b. On or about February 27, 2010, defendant Alex S.Lee, in a written statement to police, admitted that he used false information to fraudulently open an account at Saks FifthAvenue and thereafter purchased merchandise using thisfraudulently opened account.

c. In total, defendant Alex S. Lee caused in excessof $40,000 in losses to credit card companies and retail storesthrough his use of the fraudulent identities and the “bust out”of the credit cards obtained with those fraudulently obtainedidentities.

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d. As described in Paragraph 102 below, defendantMatthew J. Kang did the credit build up for both Chineseidentities possessed and used by defendant Alex S. Lee.

94. Defendants Yong Kim Lee and Hi-Joo Yang

a. On or about October 3, 2009, at approximately12:17 p.m., a law enforcement officer conducting surveillancenear the Bergen Turnpike Office observed and video recordeddefendants Seung-Ho Noh and Yong Kim Lee exit a car, driven byanother person, and enter a driveway leading to the BergenTurnpike Office.

b. On or about October 3, 2009, at approximately11:28 a.m., over the First Park Facility, defendant Sang-HyunPark received an incoming telephone call from defendant Seung-HoNoh. During this intercepted conversation, defendant Seung-HoNoh asked for directions to defendant Sang-Hyun Park’s BergenTurnpike Office. Defendant Hyun-Jin LNU told defendant Seung-HoNoh that the “woman [the customer accompanying defendant Seung-HoNoh] has the address.”

c. On or about April 15, 2010, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Yong Kim Lee. During this interceptedconversation, defendant Yong Kim Lee stated she wanted tointroduce a customer to defendant Sang-Hyun Park. They agreed tomeet on April 22, 2010. During this conversation, defendant YongKim Lee stated the customer is filing for bankruptcy and “[thecustomer] has been making payments on the cards but they are allmaxed out.” Defendant Sang-Hyun Park replied, “Bring them to me.. . . Bring the cards, I will help [the customer].”

d. On or about April 22, 2010, law enforcementofficers were conducting surveillance near the Bergen TurnpikeOffice. The officers observed a car registered to defendant Hi-Joo Yang pull into the Bergen Turnpike Office’s adjacent parkinglot with two occupants in the car (one male and one female). After approximately 50 minutes, the car departed, was followed toLinden, New Jersey, and defendant Yong Kim Lee was photographedexiting the car.

e. On or about April 27, 2010, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Hi-Joo Yang. During this conversation,defendant Hi-Joo Yang reminded defendant Sang-Hyun Park that theyhad met on April 22, 2010 with defendant Yong Kim Lee.

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f. On or about April 28, 2010, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Yong Kim Lee. During this conversation,defendant Yong Kim Lee stated, “You know Deacon Yang [defendantHi-Joo Yang] . . . . about doing the bank, he is concerned aboutsomeone knocking [on] his door, nothing like that would happen,right?” Defendant Sang-Hyun Park replied, “Nothing like thatwould ever happen.” Defendant Yong Kim Lee then stated, “Irecommended to him that it would be better to just do it promptlythan borrowing money just to make payments. Anyway, he is goingto come see me tomorrow to open another bank account.” DefendantSang-Hyun Park stated that he [defendant Hi-Joo Yang] calledyesterday.

g. On or about April 30, 2010, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Yong Kim Lee. Defendant Yong Kim Lee statedthat defendant Hi-Joo Yang “is withdrawing cash from whatever isleft over from the credit . . . . so I told him that Mr. JimmyPark is honest because unlike other [schemers] who would take out[money] without keeping him [Hi-Joo Yang] in the loop. By theway, the Deacon [Hi-Joo Yang] is not himself at the movement . .. . [chuckles] because he is concerned about committing sinsbefore God [chuckles].”

h. According to records from Bank of America, on orabout May 1, 2010, a Bank of America credit card issued on thename of defendant Hi-Joo Yang was used to obtain a $3,000 cashadvance.

i. According to records from Chase Bank, on or aboutMay 1, 2010, in Whitestone, New York, a Chase Bank credit cardissued on the name of defendant Hi-Joo Yang was used to obtain a$1,300 cash advance.

j. According to records from Chase Bank, on or aboutMay 1, 2010, a Chase Bank credit card issued on the name ofdefendant Hi-Joo Yang was used to obtain $500 through a cashadvance (ATM) on a second Chase Bank credit card.

k. On or about May 1, 2010, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Yong Kim Lee. During this conversation,defendant Yong Kim Lee stated that she had received all of thedocuments and the card from defendant Hi-Joo Yang, and she agreedto mail these items to defendant Sang-Hyun Park at the BergenTurnpike Office. On or about May 4, 2010, over the First Park

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Facility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant Yong Kim Lee and confirmed his receipt of thedocuments.

l. On or about May 4, 2010, over the First ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant Hi-Joo Yang. During this conversation,defendant Hyun-Jin LNU stated, “I have some question for you . .. .among your Chase cards . . . . Circuit City Reward . . . . thecard . . . . what’s the limit on that card?” Defendant Hi-JooYang replied, “It has $6,900.”

m. On or about May 4, 2010, according to records fromBank of America, a check payment was made in the amount of $6,800toward defendant Hi-Joo Yang’s Bank of America account. On orabout May 6, 2010, a check payment was made in the amount of$2,000 toward defendant Hi-Joo Yang’s Bank of America account.These payment were returned for insufficient funds.

n. From on or about May 7 through May 10, 2010,according to records from Chase Bank, multiple telephone andonline payments were made toward defendant Hi-Joo Yang’s ChaseBank credit card accounts, including payments in the approximateamounts of $4,200, $2,300, $2,000, $1,000, and $5,400. All of these payment were returned for insufficient funds.

o. On or about May 8, 2010, the following creditcard charges were made against several Chase credit cards issuedto defendant Hi-Joo Yang:

Merchant Approximate Amount

Cocoxu $782

A liquor store in Palisades Park , NewJersey (see Paragraph 41q below)

Charge made on or about May 8, 2010

$2,246

A liquor store in Fort Lee, New Jersey $3,735

p. In total, in or about May 2010, numerous chargeswere made against several credit cards issued to defendant Hi-JooYang. These charges were not paid, resulting in a total loss ofapproximately $50,000.

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q. On or about May 8, 2010, a law enforcement officerwas conducting surveillance near a liquor store in PalisadesPark, New Jersey. During this surveillance, the law enforcementofficer observed and video recorded defendant Hyun-Jin LNU exitthe liquor store with six cases of Johnny Walker whiskey (beingcarried by a store employee). Thereafter, defendant Osung Kwonwas observed and video recorded loading the six cases of liquorinto a black Mercedes-Benz SUV. The law enforcement officer thenfollowed defendants Hyun-Jin LNU and Osung Kwon drive back to theBergen Turnpike Office.

95. Defendant Kyung-Ki Kim

a. On or about July 8, 2010, defendant Kyung-Ki Kimentered Valley National Bank, in Fort Lee, New Jersey, andattempted to open a checking account using a counterfeitCalifornia driver’s license in the name of Yuting Zhao with acorresponding 586 social security number. The bank contacted thelocal police, who questioned defendant Kyung-Ki Kim and told himthat the driver’s license was counterfeit. Thereafter, headmitted that his real name was Kyung K. Kim and that he paid$1,500 for the counterfeit California driver’s license. Defendant Kyung-Ki Kim further admitted that he drove to thebank, and his car was parked nearby. Thereafter, police officersapproached the car and observed an individual, later identifiedas defendant Osung Kwon, sleeping in the car. When police askeddefendant Osung Kwon for his identification, he provided theofficers with defendant Kyung-Ki Kim’s New Jersey driver’slicense and then falsely claimed that the driver’s licensebelonged to him. Thereafter, police searched defendant OsungKwon’s wallet and found a New Jersey driver’s license and a ChaseVisa debit card, both in the name of another person . Later,during a video taped interview of defendant Kyung-Ki Kim by lawenforcement, he admitted that he purchased the counterfeitdriver’s license from defendant Sang-Hyun Park.

b. In addition, the investigation has revealed thatdefendant Kyung-Ki Kim “busted out” credit cards in his own name,through the assistance of defendants Sang-Hyun Park and Min-SooSon, and other co-conspirators. Defendant Kyung-Ki Kim appliedfor and received credit cards from various banks, credit cardcompanies, and retail stores, including Bank of America, CapitalOne Bank, Chase, Macy’s, Kohls, Home Depot, and Nordstrom, amongothers. After obtaining these credit cards, defendant Kyung-KiKim made charges on credit card. On or about December 18, 2009, according to bank records and a photograph from Bank of America’ssurveillance video, defendant Min-Soo Son entered a Bank ofAmerica branch in Englewood, New Jersey and made a payment, in

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the form of a check drawn on the account of Erins Skin Care,Inc., in the amount of $7,825, toward defendant Kyung-Ki Kim’sBank of America credit card. On or about December 24, 2009, thischeck was returned for insufficient funds. After the bankcredited this payment but before it was returned because ofinsufficient funds, defendant Kyung-Ki Kim’s Bank of America credit card was used to make numerous charges, including chargesLi Nails Plus (on or about December 19, 2009 in the amount ofapproximately $5,121.94) and New M&K Global (December 21, 2009 inthe amount of $2,520.24). In total, defendant Kyung-Ki Kim andhis co-conspirators obtained approximately $45,000 from thecredit cards referred to above by “busting out” these creditcards.

96. Bank Fraud—Check-Kiting (i.e., “Check Jobs”)

a. In addition to committing credit card fraud, asdescribed above, the Park Criminal Enterprise and its co-conspirators use the fraudulently obtained identities andidentity documents, including counterfeited identities, to commitbank fraud to enrich themselves and their co-conspirators. Infurtherance of this scheme, the Park Criminal Enterprise openedchecking accounts and to obtained checkbooks in Chinese nameswith corresponding 586 social security numbers (hereinafter “586Accounts”). Thereafter, the Park Criminal Enterprise and its co-conspirators deposited and attempted to deposit checks, drawn on 586 Accounts, into other 586 Accounts. These checks were drawnagainst accounts with non-existent funds. After depositing thesefraudulent checks, the Park Criminal Enterprise and its co-conspirators withdrew and attempted to withdraw cash from these586 Accounts before the bank discovered the checks to befraudulent. The following paragraphs provide example where thePark Criminal Enterprise and its co-conspirators committed andattempted to commit bank fraud through kiting checks:

Approximate Date Description

July 24, 2009 Defendant Hyun-Jin LNU opened and caused tobe opened a business checking account atWachovia Bank, Rutherford, New Jersey, in thename Citi Apparel Distributor, using the name“Hai Hua Xu,” a corresponding 586 socialsecurity number, the identification card sheobtained through the IDMV, a taxidentification number (the same 586 socialsecurity number corresponding to Hai Hua Xu),and her previous address.


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January 4, 2010 According to bank records and a photographfrom the bank’s surveillance video, defendantHyun-Jin LNU deposited a check, drawn on aaccount belonging to Limin Sun (a namecorresponding to a 586 social securitynumber), in the amount of approximately$4,920 and payable to Citi Fashion, whichcheck was deposited into the Citi FashionWholesale Account. This $4,920 was returnedfor insufficient funds.

January 4, 2010 According to bank records and a photographfrom the bank’s surveillance video, defendantHyun-Jin LNU cashed a check, drawn on theCiti Fashion Wholesale Account, in the amountof $2,400 and made payable to “cash.”

January 5, 2010 According to bank records and a photographfrom the bank’s surveillance video, defendantHyun-Jin LNU deposited a check, drawn on aaccount belonging to Limin Sun (a namecorresponding to a 586 social securitynumber), in the amount of approximately$3,000 and payable to Citi Fashion, whichcheck was deposited into the Citi FashionWholesale Account. This $3,000 check wasreturned for insufficient funds.

January 5, 2010 According to bank records and a photographfrom the bank’s surveillance video, defendantHyun-Jin LNU cashed two check, both drawn onthe Citi Fashion Wholesale Account, in theamounts of $3,000 and $1,500 and both madepayable to “cash.” In total, through thischeck-kiting scheme, defendant Hyun-Jin LNUdefrauded Wachovia Bank, causing a loss ofapproximately $6,900.


104

March 8, 2010 According to bank records and photographsfrom Chase Bank, Ridgefield, New Jersey,defendant Osung Kwon opened a businesschecking account in the name of USA Apparelusing the name “Xiaoling Zhang,” acorresponding 586 social security number, acounterfeit Nevada driver’s license, anddefendant Osung Kwon’s home address.According to records from Immigration andCustoms Enforcement (hereinafter “ICE”),defendant Osung Kwon is an illegal alien whoentered the United States from the Republicof Korea and was never issued a socialsecurity number.

April 29, 2010 According to records from Bank of America anda photograph from the bank’s surveillancevideo, defendant Joong-Hyun Jung entered aBank of America branch in Leonia, New Jerseyand, deposited a check from USA Apparel (seeParagraph directly above, dated March 8,2010, regarding this account), in the amountof $6,291.55, into a business accountbelonging to a co-conspirator in Los Angeles,California. According to records from theBank of America, this account, at the time ofthe transaction, was overdrawn byapproximately $5,100.

May 6, 2010 Defendant Joong-Hyun Jung entered a ChaseBank branch in Ridgefield, New Jersey and,according to bank records and a photographfrom the bank’s surveillance video, depositeda check drawn on a company registered to aChinese name with a corresponding 586 socialsecurity number, in the amount of $7,690.70,into a business account belonging to USAApparel Inc.


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June 25, 2010 According to records from Valley NationalBank and a photograph from the bank’ssurveillance video, defendant Osung Kwonentered a Valley National Bank in BergenCounty, New Jersey and deposited a check inthe amount of $6,000, drawn on the account of“Cheng Yu Ma,” into the account in the nameof Meihong He [defendant Hye-Won Jun’sChinese alias]. This check was returned forinsufficient funds.

The Credit Build Up Teams

97. Your Affiant’s investigation has revealed that theability of the Park Criminal Enterprise to commit credit cardfraud, bank fraud, and other financial frauds is directly tied tothe individuals and entities who build the credit scores of thefraudulently acquired Chinese identities (see Paragraph 48 for anexplaining of how the build up was accomplish). As part of thisprocess and to ensure its success, the individuals who buildcredit scores make false statements and representations to creditreporting agencies and others. For example, to establish anaddress history for the fraudulently obtained Chinese identitiesand corresponding 586 social security number, an essentialelement of the credit build up, the individuals involved in credit build up knowingly made false statements concerning theresidency of these identities.

98. After the Chinese identity is attached to the primaryaccount (i.e., the individual’s credit card account who isengaged in the credit build up), the credit card company issued acredit card, in the name of the Chinese identity, to the addressprovided by the primary account holder. These credit cards,however, are not used.

99. After the credit score related to the Chinese identityhad been increased, the individual involved in the build upremoved these identities from their primary account to preventthe primary account from being negatively effected by theimpending “bust out” activity.

100. By attaching these identities to their credit cardaccounts, the individuals involved in the credit build up causedthe credit scores associated with these fraudulently obtainedChinese identities to be artificially and fraudulently increased

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for the purpose of committing financial fraud, including bank andcredit card fraud.

101. On or about September 16, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from an unknown co-conspirator. During thisintercepted conversation, the unknown co-conspirator asked,“Then, president, can’t you rush the build up guys?” DefendantSang-Hyun Park replied that the build up was finished but pendingan address verification. The unknown co-conspirator asked,“[D]on’t the build up people do changing of the address aswell?,” and Sang-Hyun Park stated that he was using a differentbuild up person “because those [last build up] guys took toolong.” Later, the unknown co-conspirator acknowledged that SaksFifth Avenue approved the card but Nordstrom denied theapplication. Defendant Sang-Hyun Park advised the unknown co-conspirator that the “reason was that Saks took Equifax, so theaddress was correct and that’s why they gave you a card but inthe case of Nordstrom, [the store] accepts [uses] Experian andwhen [the store] looked at Experian, the address didn’t match.” The unknown co-conspirator asked Sang-Hyun Park if he could“rush” the build up of the credit score by offering more money. Defendant Sang-Hyun Park replied, “Of course, we have to do itquickly [b]ut I have to get that done, too, so I can get my 50%.”

102. Defendant Matthew J. Kang

a. On or about September 14, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from defendant Matthew J. Kang. During thisintercepted conversation, defendant Sang-Hyun Park askeddefendant Matthew J. Kang “[c]an you take any 586 customers?” Defendant Matthew J. Kang replied, “Well, I think, should we waituntil [the customer] gets through?,” and defendant Sang-Hyun Parkagreed. Defendant Matthew J. Kang then asked defendant Sang-HyunPark if “they prepare[d] the IDs at that end, yet?,” and Sang-Hyun Park replied, “[I was told] the IDs will come this Friday.”

b. On or about September 23, 2009, over the FirstPark Facility, defendant Sang-Hyun Park received an incomingtelephone call from defendant Matthew J. Kang. During thisintercepted conversation, defendant Sang-Hyun Park stated, “Ihave to go to Macy’s and a few other places. Aren’t you gonna dothe banks?” Defendant Matthew J. Kang replied, “I did one atCiti . . . .[t]he others didn’t look so good so I intentionallydidn’t do them.” Defendant Sang-Hyun Park then asked for thepassword and identification for a customer’s credit report.

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c. On or about November 4, 2009, over the First ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant Matthew J. Kang. During this intercepted phoneconversation, the following discussion ensued, in substance andin part:

Kang: Yes, President Park. How are you?Park: Yes, Mr. Kang.Kang: You’ve been busy. Yes, yes. I’m calling to

see if you got the IDs and stuff.Park: I just talked to [the person] and [the

person] said it’s coming on Saturday.Kang: Saturday?Park: Yes.Kang: I see . . . . Call me.Park: Yes.Kang: And, you, you said it’s hard to bust out the

Chase cards, right?Park: No, it doesn’t matter. . . . [I]t doesn’t

matter but [they do] chargeback so [you] needto buy a merchandise and resell it.

Kang: Ah!Park: It’s hard to get it out from Chase. Of

course cash advance, it wouldn’t matter ifthe limit for cash and purchase are thesame.

Kang: Yes, yes.Park: However, if the limit is $5,000 . . . . cash,

cash is like $1,500, then the rest has to bedone through buying merchandise.

Kang: Mm-mm.Park: [I]’m saying you can’t swipe on our machine. Kang: Ah, to buy merchandise the person needs to go

around him/herself and make the purchase.Park: Right, right.

d. On or about April 14, 2010, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from Matthew J. Kang. During this intercepted conversation,the following discussion ensued, in substance and in part:

Park: I have something that I have to build up.(emphasis added).

Kang: Oh. I see.Park: I told you about it last week.Kang: Yes. . . .

* * * *

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Park: Also, 3 or 4 customers of ours got theirs[accounts] closed. They don’t own cards. Ilooked at their files and they had problemswith their accounts with another major bank,Citibank, or they didn’t make payments fortheir cards.

Kang: It seems that way.Park: So I think the computer networks of Citi and

BoA may be collaborating. Or as you said BoAreviews their own files of the customers andif they are deeply in debt or–

Kang: As I understand it, banks don’t sharedetailed information of customers but thecredit report is open to all. It seems thatthey review it . . . . They collaborate withcredit report companies and exchangeinformation rapidly. I don’t understand itbut it seems that’s what they do. Anyway,that’s it. Hahaha.

Park: Then I will later today– Kang: Please call me later.Park: I sold all the liquor for the lady and I’ll

summarize the task for you. When should Igive you the build up tasks for 4 people? (emphasis added).

Kang: The earlier the better.Park: Okay. This week.

* * * *

Kang: You took almost $14,000 out for the lady . .. . that she can take home?

Park: What I bought the liquor with?Kang: Yes. You took a lot out. [a reference to

fraudulently obtained money](emphasis added).Park: We took a lot out.Kang: Yes.Park: I will give you a clean account for that.Kang: Okay. Do what you have to do.Park: I will call you back.Kang: Okay. Thank you.Park: Okay.

e. On or about April 14, 2010, over the First ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant Matthew J. Kang. During this interceptedconversation, defendant Sang-Hyun Park stated, “I got them allready. I finished putting together the ladies. . . . [They] have

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charged about $26,000 at that time.” Defendant Matthew J. Kangreplied, “I thought so.” [Based on this conversation, YourAffiant believes that defendant Sang-Hyun Park was referring tomoney, specifically $26,000, that had been obtained through“busting out” credit cards]. Defendant Sang-Hyun Park thenstated, “So, I owe you $13,000 something,” and defendant MatthewJ. Kang replied, “Yes.” They agreed to meet later that day at acoffee shop next to Cello Hair.

f. On or about April 14, 2010, a law enforcementofficer was conducting surveillance near Cello Hair, in PalisadesPark, New Jersey. During this surveillance, the law enforcementofficer observed and video recorded defendant Matthew J. Kangmeeting with defendant Hyun-Jin LNU in a coffee shop next toCello Hair.

g. During this investigation, federal agents obtainedrecords from American Express, Citibank, and credit reportingagencies pertaining to credit card accounts belonging todefendant Matthew J. Kang (using the name “Matthew J. Kang”). These records reveal that beginning in or about July 2007defendant Matthew J. Kang has attached at least 70 individuals tohis credit card accounts as authorized users. The vast majorityof the names attached to defendant Matthew J. Kang’s accounts areChinese names with corresponding 586 social security numbers. These Chinese names were removed from his credit card accountsbefore the credit cards were used to commit fraud, as follows:

Chinese Name/SSN

Real Identity Remarks

“J.Z.”

586

CooperatingWitness One

Cooperating Witness Onepurchased a 586 socialsecurity card andcounterfeit Californiadriver’s license in thename of “J.Z.” from defendants Sang-Hyun Parkand Hyun-Jin LNU on orabout May 8, 2010.

Chinese Name/SSN


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“D.M.L.”

586

Undercover Agent The Undercover Agentpurchased a 586 socialsecurity card andcounterfeit Californiadriver’s licenses in thename of “D.M.L.” fromdefendants Sang-Hyun Parkand Hyun-Jin LNU.

Yulan Qian

586

Defendant AmyYang

Defendant Amy Yang usedthis fraudulent identity(Yulan Qian), together witha counterfeit Nevadadriver’s license andcorresponding 586 socialsecurity number, to open anaccount at Valley NationalBank. She also used thisfraudulently obtainedidentity to obtainapproximately two creditcards.

Yuting Zhao

586

Defendant Kyung-Ki Kim

Defendant Kyung K. Kim toldpolice officers that hepaid defendant Sang-HyunPark $1,500 for acounterfeit Californiadriver’s license with acorresponding 586 socialsecurity number in the nameof Yuting Zhao. DefendantKyung K. Kim was arrestedas he attempted to open abank account using thisfraudulently obtainedidentity.

Fei Chen

586

Defendant Young-Woo Ji

Defendant Young Woo Jiobtained a driver’s licensefrom the IDMV using a 586social security number notissued to him.

Chinese Name/SSN


111

Yicun Zhu

586

Alex S. Lee Defendant Alex S. Lee usedthis fraudulent identity(Yican Zhu), acorresponding 586 socialsecurity number, and acounterfeit Californiadriver’s license, to open aline of credit at SaksFifth Avenue, in BergenCounty, New Jersey. Inaddition, defendant Alex S.Lee used this fraudulentidentity to obtain a chargeaccount at PC Richard andSon, which credit card wasused to purchase a flatscreen television.

Yun Hu

586

Alex S. Lee Defendant Alex S. Leeattempted used thisfraudulent identity (YunHu), together with afraudulently obtainedPennsylvania driver’slicense and corresponding586 social security number,to open a line of credit atSaks Fifth Avenue, inBergen County, New Jersey.

Meihong He

586

Defendant Hye-WonJung

Defendant Hye-Won Jung usedthis fraudulent identity (Meihong He) and acorresponding 586 socialsecurity number, to obtainapproximately ten creditcards and lines of creditfrom various credit cardcompanies and retailstores. These charges werenot paid, resulting in atotal loss of approximately$8,000.

Chinese Name/SSN


112

Run Hong Liu

586

Defendant Song-JaPark

Defendant Song-Ja Park,used this fraudulentidentity (Run Hong Liu), acorresponding 586 socialsecurity number, and acounterfeit Nevada driver’slicense, to open an accountat Chase Manhattan Bank, inBergen County, New Jersey.

103. Defendant Rita S. Kim and Hyon-Suk Chung

a. During this investigation, federal agents obtainedrecords from American Express, Citibank, and credit reportingagencies pertaining to credit card accounts belonging todefendants Rita S. Kim and Hyon-Suk Chung, owner/operators ofShin Yong Consulting, LLC, d/b/a Shin Hwa Consulting. These records reveal that beginning in or about July 2008,defendants Rita S. Kim and Hyon-Suk Chung have attached at least65 individuals to their credit card accounts as authorized users. The vast majority of the names attached to their accounts areChinese names with corresponding 586 social security numbers. These Chinese names were removed from their credit card accountsbefore the credit cards were used to commit fraud, as follows

Chinese Name/SSN


“Y.L.” CooperatingWitness One

Cooperating Witness Onepurchased a 586 socialsecurity card then use itto obtain an Illinoisdriver’s license.

“Y.F.Z.”

586

CooperatingWitness Two

Cooperating Witness Twopurchased a 586 socialsecurity card andcounterfeit Nevada driver’slicense in the name of“Y.F.Z.” from defendantsSang-Hyun Park, Hyun-JinLNU, and Young-Hee Ju.

Chinese Name/SSN


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Zhankun Liu

586

Dong-Il Kim Defendant Dong-Il Kimobtained a driver’s licensefrom the IDMV using a 586social security number notissued to him in the nameof Zhankun Liu.

Qing Yun Wang

586

unknown In or about July 2009, theQing Yun Wang identity wasattached to defendant Hyon-Suk Chung’s Citibank creditcard as an authorized user.

Dongshu Li

586

Jong-Kwan Hong Defendant Jong-Kwan Hongused the Chinese nameDongshu Li, a corresponding586 social security numbernot issued to him, and acounterfeit Nevada driver’slicense to open accountsand obtain credit cards.

Dongshu Li

586

Jong-Kwan Hong In or about mid-2009, theDongshu Li identity wasattached to defendant RitaS. Kim’s Citibank creditcard as an authorized user.

Wei Yun Zhong

586

Dong-Won Kim Defendant Dong-Won Kimobtained a driver’s licensefrom the IDMV using a 586social security number notissued to him in the nameof Wei Yun Zhong.

In or about mid-2009, theWei Yun Zhong identity wasattached to defendant RitaS. Kim’s Citibank creditcard as an authorized user.

Chinese Name/SSN


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Cheng Yu Ma

586

unknown This Chinese identity wasused to commit a variety offrauds (see Paragraphs 84e,89h, and 96 above).

In or about mid-2009, theCheng Yu Ma identity wasattached to defendant RitaS. Kim’s Citibank creditcard as an authorized user.

104. Defendant Young-Woo Ji

a. As described above in Paragraphs 8, defendantYoung-Woo Ji conspired with defendant Sang-Hyun Park to do thecredit build up for defendant In-Sook Lee’s Chinese identity,Ping Fang.

b. On or about October 3, 2009, over the First ParkFacility, defendant Sang-Hyun Park spoke with defendant Hyun-JinLNU (using another co-conspirator’s cellular telephone). Duringthis intercepted conversation, defendants Sang-Hyun Park andHyun-Jin LNU discussed the status of credit build ups/addressverifications being worked on by defendant Young-Woo Ji. Defendant Sang-Hyun Park instructed her to not inquire into acustomer’s credit history because it lowers the credit score. Defendant Sang-Hyun Park stated, “The rest should be done likeyou said. He [defendant Young-Woo Ji] treated the money that wasgiven like this: [defendant Yong Kim Lee and another customer] .. . are $500 and $500, so it’s $1,00 total, but he [defendantYoung-Woo Ji] settled with $800 sent that time. . . .” Laterduring the conversation, defendant Sang-Hyun Park stated, “Iheard [defendant Young-Woo Ji] asked you to send some documentover . . . . bill and . . . in order to put the address ofhimself, he needs [the] bill and a bank payment. . . . . Once he[defendant Young-Woo Ji] can verify the address and finish thebuild up, that address will show up [on the customer creditreport]. . . . About the two build up [sic] that went into[defendant Young-Woo Ji] in order for those to [appear on thecustomer’s credit report] he needs two proof[s] of residence.” Defendant Hyun-Jin LNU acknowledged that she understood.

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The Collusive Merchants–“Kkang”

a. In furtherance of the scheme, the Park CriminalEnterprise and its co-conspirators use credit card machines toobtain money by charging or “swiping” the fraudulently obtainedcredit cards. To carry out the scheme, the collusive merchantenters into a contract with a Merchant Bank (often referred to asAcquiring Bank) and sets up an account with the Merchant/Acquiring Bank. This account allows all approved credit cardtransactions conducted by the collusive merchant to be processedand deposited into the collusive merchant’s bank account, andthen, transferred into the collusive merchant’s business bankingaccount. On a daily basis, the Merchant/ Acquiring Bank willreceive all authorized credit card transactions from thecollusive merchant and settle (obtain payment) from therespective credit cards entities. Thereafter, the Merchant/Acquiring Bank deposits the proceeds into the collusivemerchant’s bank account.

b. As part of the scheme, the Collusive Merchantsoften change merchants and routinely change the names of theirentities to avoid detection and scrutiny by law enforcement.

105. Defendant Sang-Hyun Park

a. On or about September 9, 2009, over the First ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to a co-conspirator (a Korean-speaking male). During thisintercepted conversation, the unknown male stated “you know thecard you worked on for “round two” [a reference to busting outcredit cards], to swipe it, how much processing fee do you take .. . . [r]ound two, that the merchant swipes?” Defendant Sang-Hyun Park responded: “I charge 20% kkang fee. . . . It is 20% nomatter what, if it’s swiping the card.” The unknown male thenstated to call him “if there is anything good” because he wantedto make some money. Defendant Sang-Hyun Park questioned theunknown male about how he uses credit cards, and the unknown malestated, “I don’t do it on the [credit card] machine. I spin[sic] it . . . . I take out the cash that I can take out. And Ibuy [gift cards].”

b. During this investigation, federal agents havereviewed the bank accounts of Cocoxu and Li Nails. DefendantSang-Hyun Park opened these accounts and is the authorizedsignatory on these accounts. These records reveal that the vastmajority of deposits into these accounts originates from creditcard transactions—i.e., credit card charges or “swipes” madethrough credit card machines. In total, from in or about June

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2009 through in or about July 2010, approximately $880,000 wascollectively deposited into these two accounts. After this moneywas deposited into these accounts, the vast majority of the moneywas either withdrawn by checks (payable to cash) or transferredthrough wire transactions. The following chart sets forth someof these wire transactions, among others:

Date of WireTransaction

From To Amount Remarks

June 16, 2009 Cocoxu bank in Seoul,South Korea

$6,000 Payment

July 22, 2009 Cocoxu bank in Seoul,South Korea

$1,300 Gift

July 22, 2009 Cocoxu bank in Seoul,South Korea

$2,000 Gift

August 19,2009

Cocoxu bank in Seoul,South Korea

$2,500 Gift

August 24,2009


$1,700 Gift

September 8,2009


$4,000 Gift

November 9,2009


$9,000 Payment

December 10,2009


$5,500 Gift

March 3, 2010 Cocoxu bank in Seoul,South Korea

$7,000 Purchase ofMerchandise

July 1, 2010 Li Nails bank in Seoul,South Korea

$1,000 None

106. Defendant Hyeon-U Kim and Sunny Enterprises

a. On or about September 14, 2009, over the FirstPark Facility, defendant Sang-Hyun Park made an outgoing phonecall to defendant Hyeon-U Kim. During this interceptedconversation, defendant Sang-Hyun Park asked how much of a creditcard charge “Sunny Enterprises swipe at one time?” DefendantHyeon-U Kim stated, “I don’t think it’s good to swipe too much,maybe $2,000,” and they agreed to swipe $2,300. Defendant Sang-Hyun Park said “we will send the invoice when we are told. It

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will be nice to get the money.” Defendant Sang-Hyun Parkconcluded the call by stating he would call back defendant Hyeon-U Kim after he swiped the card.

b. As described above, a fraudulently obtained creditcard in the Y.L. Identity [Cooperating Witness One] was chargedto Sunny Enterprises.

107. Defendant Hyo-Il Song—153 Samsung DC and 90 You and Me

a. 153 Samsung DC, Inc. was incorporated in NewJersey under the name Haizhe Pei, an identity used by defendantHyo-Il Song.

b. On or about December 21, 2009, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Hyo-Il Song. During this interceptedconversation, defendant Sang-Hyun Park stated that he needed to“swipe the card one more time for about $5,000. . . . That’s theremaining available balance.” Defendant Hyo-Il Song stated thathe would go to defendant Sang-Hyun Park’s location, and defendantSang-Hyun Park stated, “If possible, I want to swipe it on yourequipment. . . . We don’t need to make other people make money.”

c. On or about December 23, 2009, over the First ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant Dong-Won Kim. During this interceptedconversation, defendant Dong-Won Kim stated, “I am on my way. Iam just . . . crossing the George Washington Bridge.” Afterdefendant Dong-Won Kim stated that the amount on the card was inexcess of $11,000, defendant Sang-Hyun Park suggested, “I amshort of equipment and have to use President Daniel’s equipmentto swipe [defendant Hyo-Il Song]. . . . Shall I tell Daniel tobring the equipment here?” Defendant Dong-Won Kim replied, “Yes,do that. And, if you need equipment, take one of mine. I haveone that can swipe up to $2,000.” During a subsequentintercepted phone call between defendants Sang-Hyun Park andDong-Won Kim later that day, defendant Sang-Hyun Park stated thathe swiped “$5,012,” and “I swiped it on Daniel’s equipment.” During yet another intercepted phone call between defendantsSang-Hyun Park and Dong-Won Kim later that day, defendant Sang-Hyun Park stated, “$4,897 was swiped at Li Nail shop. . . . [A]nd$5,012 was swiped at You and Me. . . . [and $1,210 was swiped atErins Skin Supply].”

d. On or about December 24, 2009, over the First ParkFacility, while off the hook and placing a call to defendantDong-Won Kim, defendant Sang-Hyun Park was intercepted making the

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following statements to unknown individuals: “You need to be onthe move, too. From $40,000, $50,000, about $27,000 is left. Soboth of you go and since it’s about $14,000, okay? Just ID . . .take 586 one, not the personal one.”

e. On or about April 12, 2010, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Hyo-Il Song, a/k/a “Daniel.” The followingintercepted conversation ensued, in substance and in part:

Park: Hello.Song: How are you, Mr. President? This is Daniel.Park: Yes, Mr. President, yes.Song: The Amex card, can we run it for $5,000?Park: Amex, $5,000.Song: What?Park: Mr. President, no machine can run an Amex

card for $5,000 with one swipe.Song: Haha. Is that so?Park: Yes.Song: Can it be done in two swipes?Park: In two swipes? Give me a minute. Just a

minute. Please wait a minute.Song: Okay.Park: Yes, sir. It is possible to do it in two

swipes.Song: Is that right? When can I bring it over?

Now?Park: That’s fine. Okay.Song: I’m coming over now.Park: OkaySong: Okay.

Your Affiant believes that during this conversation, defendantsSang-Hyun Park and Hyo-Il Song were discussing “busting out”(i.e., “swiping”) an American Express credit card. During theinvestigation, it was determined that defendant Sang-Hyun Parkmaintains credit card machines at his offices for the purpose offraudulently charging fraudulently acquired credit cards.

e. According to financial records related to “90 Youand Me,” approximately $78,000 in deposits were made into thisentity’s account.

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108. Defendant Edward M. Ha

a. On or about October 2, 2009, over the First ParkFacility, defendant Sang-Hyun Park received an incoming telephonecall from defendant Matthew J. Kang. During this interceptedconversation, defendant Matthew J. Kang stated that a card wasswiped for $1,700 at an “accountant’s office . . . . 730 GrandAve., it’s Ridgefield, Ridgefield. . . . the [customer] is sayingin way that it was a tax payment, for a payment.”

b. On or about March 28, 2010, a law enforcementofficer conducted surveillance at 730 Grand Avenue, Ridgefield,New Jersey. This surveillance revealed that defendant Edward M.Ha, a certified public accountant, maintains a suite at thislocation.

c. On or about November 11, 2009, over the First ParkFacility, defendant Sang-Hyun Park made an outgoing telephonecall to defendant Matthew J. Kang. During this interceptedconversation, defendant Sang-Hyun Park placed defendant Hyun-JinLNU on the phone, and she spoke with defendant Matthew J. Kang. Defendant Hyun-Jin LNU stated, “Earlier, you included oneadditional person . . . . Chunyu An . . . . You didn’t give thisperson’s credit card information.” Defendant Matthew J. Kangthen provided the information.

d. According to records from Macy’s/Bloomingdale’s,at least two credit cards were issued to an individual using thename Chunyu An, a 586 social security number, an Nevada driver’slicense [later determined to be counterfeit], and an addressbelonging to defendant Matthew J. Kang. According to theserecords, these two credit card were used to conduct the following transactions:

Date Amount Transaction Information

January 5, 2010 $2,000 Edward M. Ha, CPA



e. According to records from Macy’s/Bloomingdale’s,the following charges were made on other credit cards associatedwith Chinese names, corresponding 586 social security numbers,and counterfeit Nevada driver’s licenses, through defendantEdward M. Ha’s business:

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October 30, 2009 $6,000 Edward M. Ha, CPA





f. According to records from Citibank, the followingcharges were made on other credit cards associated with Chinesenames, corresponding 586 social security numbers, and counterfeitNevada driver’s licenses, through defendant Edward M. Ha’sbusiness (except as described below):


September 25,2009

$20,000 Edward M. Ha, CPA

October 5, 2009 $4,800 Edward M. Ha, CPA

October 16, 2009 $8,500 Edward M. Ha, CPA(corresponding to a credit cardissued to defendant Hyo-IlSong, which credit card was“busted out”)

g. According to records from TD Bank, the followingcharges were made TD Bank credit cards issued to Chinese namesand corresponding 586 social security number, as follows:


February 9, 2010 $2,500 Edward M. Ha, CPA

February 17, 2010 $8,500 Edward M. Ha, CPA

March 3, 2010 $5,000 Edward M. Ha, CPA

121

h. All of the credit cards used to conduct thetransactions described above at defendant Edward H. Ha’s business were “busted out.”

i. Based on the above, Your Affiant submits that defendant Edward M. Ha is a collusive merchant who used hisaccounting business’ credit card machine to engage in “kkang.”

109. FNU LNU#1 (a/k/a “Xijun Gu”)

a. According to records from a merchant bank,defendant FNU LNU#1, using the Chinese name Xijun Gu, acorresponding 586 social number, and a business address (i.e.,the Bergen Boulevard Office) formerly used by defendant FNU LNU#1and defendant Sang Hyun-Park (as determined by surveillance),applied for and obtained a merchant bank account in the name of“For Your Joy.” On this application, defendant FNU LNU#1represented that his business was a clothing wholesale businesslocated at the Bergen Boulevard Office. Cooperating Witness Oneentered this office on several occasions and never observed anyevidence of a clothing business. Furthermore, according to theserecords, defendant FNU LNU#1 used Cocoxu (defendant Sang–HyunPark’s shell company) as a reference.

b. According to financial records related to “ForYour Joy,” from in or about April 2009 though in or about March2010, approximately $363,000 in deposits were made into thisentity’s account.

122

The Scheme to Defraud the United States–Internal Revenue Service

110. On or about April 8, 2010, a Form 1040 EZ, IndividualIncome Tax Return, was electronically filed with the InternalRevenue Service in the name of Jian F. Jiang, with acorresponding 586 social security number. This name and socialsecurity number were used by defendant Sang-Hyun Park to obtainan Illinois identification card, as described in Paragraph 51above. This return claimed a tax refund of approximately $3,258. The electronically filed return was accompanied by a Form W-2,claiming that Jian F Jiang was employed by Ameth Thread, locatedin Palisades Park, New Jersey, a company incorporated bydefendant Sang-Hyun Park. Furthermore, federal agents traced theInternet Provider address (hereinafter “IP address”) related tothis return, and, according to the Service Provider, thesubscriber of that IP address was defendant Sang-Hyun Park, usingan address of an apartment in Flushing, New York (hereinafter the“Flushing Address”). The Internal Revenue Service determinedthat the return was filed from the Flushing Address. TheInternal Revenue Service did not pay this refund. Furthermore, According to the Internal Revenue Service, in 2010, several otherForms 1040 EZ were electronically filed or transmitted from the Flushing Address, using same IP address traceable to defendantSang-Hyun Park. Each return claimed a refund and was filed witha name corresponding to a 586 social security number, as follows:

ApproximateDate ReturnFiled

Name and SSNon Return

DefendantAssociatedwithIdentity

AmountClaimed/Received

PurportedEmployer

March 6,2010

Zhanhong Fan

586 SSN

Sung-Sil Joh $1,904$1,829.19

Big BuyEnterprise,Inc.,LittleFerry, NJ

April 8,2010

Ping Fang

586 SSN

In-Sook Lee $2,996$2,996

Image NailSpa, Inc.,CliffsidePark, NJ

April 8,2010

Hong Y. Xu

586 SSN

unknown $3,258$0

500 JokerBilliardLLC,PalisadesPark, NJ





PurportedEmployer

123

April 13,2010

Guizhen Guo

586 SSN

unknown $3,616$0

Blue StarMeat Corp.,Bronx, NY

April 13,2010

Shan J. Jin

586 SSN

unknown $3,473$0

Blue StarMeat Corp.,Bronx, NY

111. According to financial records pertaining to theabove-referenced electronically filed tax returns, the purportedtax payer elected to have the refunds electronically depositedinto prepaid card accounts, which accounts are similar to giftcards. These prepaid card accounts were mailed to addresseslocated in New York different that the address reported on thetax return.

112. According to the Internal Revenue Service, in 2010,several other Forms 1040 EZ were electronically filed ortransmitted to the Internal Revenue Service. Each return claimeda refund and was filed with a name corresponding to a 586 socialsecurity number, as follows:





PurportedEmployer

January 21,2010

Longnan Cui

586 SSN

Myung-KyunKo

$9,404$0

JasperEnterprises,Long IslandCity, NY

January 22,2010

Zhen S. An(ZhengshuAn)

586 SSN

Jong-HoonKim

$8,300$0

HarrahsEntertain-ment, Inc.

January 27,2010

Mingyu Jin

586 SSN

Sang-HyunPark andHye-Won Jung

$9,625$0

MGM Mirage,Las Vegas,NV





PurportedEmployer

124

February 2,2010

ZhaofangChen

586 SSN

Jin LNU,a/k/a “Jin”

$8,931$0

Dover DownsGamingEntertain-ment, Dover,DE

February 3,2010

Wei Xiang Lu 586 SSN

Jung-BongLee

$8,985$8,985

EastmanKodak,Rochester,NY

February11, 2010

Zhankun Liu

586 SSN

Dong-Il Kim $6,040$0

Home Depot,Atlanta, GE

February18, 2010

ShanjiLi

Hyun-YopSung

$8,944$0

MoheganTribalGamingAuthority,Uncasville,CT

February19, 2010

Ming H. Li

586 SSN

Hyo-Il Song $9,916$0

SignalEnterpriseCorp.,ValleyStream, NewYork

March 26,2010(Tax returne-filedfrom an IPaddresslocated at an addressin Bayside,New Yorkused bydefendant Young WooJo, a/k/a“Fei Chen”)

Cheng Y.Ma

unknown $3,303$3,303

AmethThread,PalisadesPark, NJ





PurportedEmployer

125

April 10,2010

(Tax returne-filedfrom an IPaddresslocated at an addressin Bayside,New Yorkused bydefendant Young WooJo, a/k/a“Fei Chen”)

Haishun Jin

586 SSN

Jung-SookKo, a/k/a“Grace S.Lim”

$3,303$0

AmethThread,PalisadesPark, NJ

April 23,2010

Xianzi Luo Chi-Won Jeon $8,331$0

n/a

113. According to the Internal Revenue Service, in2008, several Forms 1040 EZ were electronically filed ortransmitted to the Internal Revenue Service. Each return claimeda refund and was filed with a name corresponding to a 586 socialsecurity number, as follows:


Name andSSN onReturn



PurportedEmployer

October 7,2009

ZhanhongFan

586 SSN

Sung-Sil Joh $6,937$6,937

TrumpEntertainmentResort,AtlanticCity, NJ

October 11,2009

Guizhen Guo

586 SSN

unknown $9,314$9,314

New SimbalCorp., Bronx,NY


Name andSSN onReturn



PurportedEmployer

126

October 15,2009

ShanjiLi

586 SSN

Hyun-YopSung

$8,967$8,967

MoheganTribal GamingAuthority,Uncasville,CT

Conclusion

114. In total, the Park Criminal Enterprise and its co-conspirators caused millions of dollars in financial losses tothe United States and banks, credit card companies, lenders, andothers.